Surface Coating of Plastic Parts for Business Machines: Background Information for Proposed Standards

A
ENVIRONMENTAL PROTECTION AGENCY

Background Information
and Draft
Environmental Impact Statement
•for the Surface Coating of Plastic Parts for Business Machines
Prepared by:
Jack R.
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EPA-450/3-85-019a
Surface Coating of Plastic Parts
For Business Machines-
Background Information for
Proposed Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711

December 1985
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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use. Copies of this report are
available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, or from National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161. -
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TABLE OF CONTENTS
Page
LIST OF FIGURES v

LIST OF TABLES vi

CHAPTER 1. SUMMARY 1-1

1.1 Regulatory Alternatives 1-1
1.2 Environmental Impact 1-3
1.3 Economic Impact 1-4

CHAPTER 2. INTRODUCTION 2-1

2.1 Background and Authority for Standards 2-1
2.2 Selection of Categories of Stationary Sources .... 2-4
2.3 Procedure for Development of Standards of
Performance 2-6
2.4 Consideration of Costs 2-8
2.5 Consideration of Environmental Impacts 2-9
2.6 Impact on Existing Sources 2-10
2.7 Revision of Standards of Performance 2-11

CHAPTER 3. THE SURFACE COATING OF PLASTIC PARTS FOR BUSINESS
MACHINES: PROCESSES AND POLLUTANT EMISSIONS 3-1

3.1 General 3-1
3.2 Factors Influencing Surface Coating of Plastic Parts . 3-3
3.3 Processes or Facilities and Their Emissions 3-7
3.4 Baseline Emissions 3-17
3.5 References for Chapter 3 3-21

CHAPTER 4. EMISSION CONTROL TECHNIQUES 4-1

4.1 Use of Lower-VOC-Content Coatings 4-2
4.2 Process Modifications 4-7
4.3 Emissions Control with Add-On Control Equipment . . . 4-14
4.4 Emission Source Test Data 4-18
4.5 References for Chapter 4 4-21

CHAPTER 5. MODIFICATION AND RECONSTRUCTION 5-1

5.1 General Provisions for Modification and
Reconstruction 5-1
5.2 Applicability to Surface Coating of Plastic Parts . . 5-2

CHAPTER 6. MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1

6.1 Model Plants 6-1
6.2 Regulatory Alternatives 6-9
6.3 References for Chapter 6 .... 6-18

i i i
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TABLE OF CONTENTS (continued)
CHAPTER 7. ENVIRONMENTAL IMPACT
Page

7-1
7.1
7.2
7.3
7.4
7.5
7.6
7.7
CHAPTER 8.
8.1
8.2
8.3
CHAPTER 9.
9.1

9.2
9.3
APPENDIX A.
APPENDIX B.
APPENDIX C.
APPENDIX D.
Air Pollution Impact
Water Pollution Impact
Solid Waste Disposal Impact
Energy Impact
Other Environmental Impacts
Other Environmental Concerns
References for Chapter 7
COSTS
Cost Analysis of Regulatory Alternatives
Other Cost. Considerations
References for Chapter 8 . -
ECONOMIC IMPACT
Profile of Industry — Surface Coating of Plastic Parts
for Business Machines
Economic Effects of Regulatory Alternatives
References for Chapter 9
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT . . .
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
EMISSION SOURCE TEST DATA
EMISSION MEASUREMENT AND MONITORING
7-1
7-5
7-6
7-7
7-7
7-8
7-23
8-1
8-1
8-3
8-24
9-1

9-1
9-23
9-77
A-l
B-l
c-i
D-l
iv
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LIST OF FIGURES
Figure 3-1 Relationship Among Industrial Sectors Involved in the
Surface Coating of Plastic Parts for Business
Machines
Figure 3-2

Figure 3-3
Figure 4-1
Figure 4-2
Figure 4-3
Figure 4-4
Figure 6-1
Figure 6-2
Figure 6-3
Figure 9-1

Figure 9-2
Figure 9-3
Figure 9-4
Figure 9-5
Figure 9-6
Figure 9-7
Figure 9-8
Figure 9-9
Figure 9-10

Coating Processes for Plastic Parts Used in Business
Machines
Typical Conveyorized Coating for Three-Coat System .
Two Unit, Fixed-Bed Carbon Adsorption System ....
Diagram of Thermal Incinerator
Catalytic Incinerator
Shell and Tube Surface Condenser
Schematic of Model Plant A
Schematic of Model Plant B
Schematic of Model Plant C
Supply Schedules for Constructed and Unconstructed
Plants
Market Equilibrium
Long-Run Supply
Market Equilibrium Without NSPS
Costs and Benefits Without NSPS ....
Market Effects of NSPS: Case I
Market Effects of NSPS: Case 2 .
Market Effects of NSPS: Case 3 ...
Market Effects of NSPS: Case 4
Cost-Effectiveness Scenarios for Regulatory
Alternatives

3-8
3-15
4-16
4-17
4-19
4-20
6-6
6-7
6-8

9-36
9-38
9-40
9-41
9-43
9-45
9-47
9-48
9-50

9-67
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LIST OF TABLES

Table 1-1
Table 1-2

Table 3-1
Table 3-2
Table 5-1
Table 6-1
Table 6-2
Table 6-3

Table 6-4

Table 7-1

Table 7-2

Table 7-3

Table 7-4

Table 7-5

Table 7-6

Table 7-7

Table 7-8

Table 7-9

Control Options Used in the Regulatory Alternatives .
Matrix of Environmental and Economic Impacts of
Regulatory Alternatives
EMI/RFI Radiation Limits Established by the FCC ...
Coating Utilization of a Typical Plant
Examples of Potential Modifications
Model Plant Parameters
Baseline Coating Utilization
Percent Coating Material Utilization for Different
Regulatory Alternatives
Emission Reduction Potential of Regulatory
Alternatives as a Function of Transfer Efficiency
Annual VOC Emissions from Model Plant A for Each
Regulatory Alternative
Annual VOC Emissions from Model Plant B for Each
Regulatory Alternative
Annual VOC Emissions from Model Plant C for Each
Regulatory Alternative
Summary of Annual VOC Emissions from Model Plants A,
B, and C for Each Regulatory Alternative
Projected Consumption of Structural Foam (SF) for
Business Machine Parts
Projected Consumption of Straight-Injection-Molded
(SIM) Plastic for Business Machine Parts
Total Nationwide VOC Emissions from the Coating of
Plastic Parts for Business Machines
Annual Solid Wastes Generated as a Result of
Overspray from the Coating of Plastic Parts for
Business Machines
Examples of Hazardous Substances Used in the
Surface Coating Process
Page
1-5

1-6
3-6
3-20
5-4
6-2
6-10

6-11

6-17

7-9

7-11

7-13

7-15

7-17

7-18

7-19.

7-21

7-22
VI
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LIST OF TABLES (continued)

Page

Table 8-1 Model Plant Parameters 8-5

Table 8-2 Basis for Estimating Installed Capital Costs for
Surface Coating of Plastic Parts Used in Business
Machines 8-8

Table 8-3 Installed Capital Costs for Regulatory Alterna-
tive I—Baseline 8-9

Table 8-4 Basis for Estimating Direct Operating Costs for
Surface Coating of Plastic Parts Used in Business
Machines 8-10

Table 8-5 Methods for Calculating Annualized Costs of Plastic
Parts Used in Business Machines 8-11

Table 8-6 Annualized Costs for Regulatory Alternative I ... 8-14

Table 8-7 Average Cost Effectiveness of Regulatory Alterna-
tives—Model Plant A 8-15

Table 8-8 Average Cost Effectiveness of Regulatory Alterna-
tives—Model Plant B 8-18

Table 8-9 Average Cost Effectiveness of Regulatory Alterna-
tives—Model Plant C 8-21

Table 9-1 Relative Size of the Industries Related to the
Surface Coating of Plastic Business Machine
Parts 9-4

Table 9-2 Historical Comparison of Value of Industry Ship-
ments for Business Machines with GNP in Constant
1972 Dollars 9-9

Table 9-3 Companies that Controlled Over Half of the Injec-
tion Foam Molding and Finishing Market in 1982 . . 9-12

Table 9-4 Representative List of Companies that Perform
Surface Coating of Plastic Business Machine Parts . 9-13

Table 9-5 Selected Financial Ratios for Small Manufacturers
of Plastic Parts 9-21

Table 9-6 Depreciation Deductions Under the Accelerated Cost
Recovery System 9-27

Table 9-7 Model Plant Cost Data 9-31
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LIST OF TABLES (continued)

Table 9-8
Table 9-9

Table 9-10

Table 9-11
Table 9-12

Table 9-13
Table 9-14
Table 9-15

Table 9-16
Table 9-17

Table 9-18
Table 9-19
Table 9-20

Table 9-21

Table 9-22

Table 9-23
Table 9-24
Table 9-25

Table 9-26

Model Parameter Values
Unit Cost of Production for Model Plants A
and B, 1990
Equilibrium Price and Quantity Values Without an
NSPS, 1990
Price Change Analysis by Regulatory Alternative . .
Plastic Parts Coating: Price and Quantity Effects,
1990
Plastic Parts Coating: 1990 Cost for Market A . .
Plastic Parts Coating: 1990 Cost for Market B . .
Plastic Parts Coating: 1990 Cost for Total
Industry
Employment Effects
Facilities with Production Output that May Be
Influenced by the Regulation
Plastic Parts Coating: Distributional Effects . .
VOC Emissions
Cost-Effectiveness of Regulatory Alternatives
for Market A
Cost-Effectiveness of Regulatory Alternatives for
for Market B
Cost-Effectiveness of Regulatory Alternatives for
Total Industry
Noninferior Regulatory Alternatives for Market A .
Noninferior Regulatory Alternatives for Market B .
Noninferior Regulatory Alternatives for Total
Industry
Sensitivity Analysis for Demand Elasticity ....
Page
9-32

9-34

9-44
9-52

9-54
9-56
9-57

9-58
9-60

9-62
9-64
9-66

9-70

9-71

9-72
9-73
9-74

9-75
9-76
vm
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1. SUMMARY

1.1 REGULATORY ALTERNATIVES
This background information document (BID) supports proposal of the
new source performance standard (NSPS) for emissions of volatile organic
compounds (VOC's) from facilities that surface coat plastic parts for
business machines. The development of standards of performance for new,
modified, or reconstructed stationary sources of air pollution was
dictated by Section 111 of the Clean Air Act (42 USC 7411), as amended.
The plastic parts coating process emits VOC's. These VOC's
participate in atmospheric photochemical reactions to produce ozone and
other photochemical oxidants. The photochemical oxidants cause, or
contribute significantly to, air pollution which may reasonably be
anticipated to endanger public health or welfare. The sources of the
VOC emissions are the decorative and protective coatings used on the
exterior surface of plastic parts and the metal-filled electromagnetic
interference/radio-frequency interference (EMI/RFI) shielding coatings
used on the interior surface of plastic parts. The VOC's used in these
coatings evaporate into the atmosphere as the coating dries.
Regulatory alternatives to reduce VOC emissions were considered.
The 32 alternatives were derived from combining each of four EMI/RFI
shielding control options with each of eight exterior coating control
options. These alternatives are presented in detail in Chapter 6. To
simplify the presentation of the regulatory alternatives, the control
options for EMI/RFI shielding and exterior coating are discussed
separately below.
The control options for EMI/RFI shielding coatings are as follows:
1. The use of organic-solvent-based metal-filled coatings containing
15 percent, by volume, solids at the spray gun;
1-1
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2. The use of organic-solvent-based metal-filled coatings containing
25 percent, by volume, solids at the spray gun;
3. The use of waterborne coatings containing 33 percent, by volume,
solids at the spray gun and a VOC-to-water volume ratio of 28:72 in the
coating; and
4. The use of zinc metal that has been melted in an electric arc
gun and blown onto a part by a jet of compressed air flowing from the
electric arc gun (zinc-arc spray).
Control option 1 for EMI/RFI shielding coatings represents the
baseline, the current industry practice in absence of an NSPS. The
coatings used in options 1 through 3 are applied at a transfer efficiency
(TE) of 50 percent (i.e., 50 percent of the coating solids sprayed
adheres to the part). The process in option 4 has a TE of 53 percent.
The control options for exterior coatings specify either a TE of
25 percent for all coats or a TE of 40 percent for the prime and color
coats and 25 percent for texture and touch-up coats. The higher TE can
be achieved by using air-assisted airless or electrostatic spray equipment
instead of the conventional air-atomized equipment. Discussion of this
equipment is presented in Chapters 3 and 4.
The control options for exterior coating are as follows:
1. The combination of coatings currently used by the coaters of
plastic parts (see Chapter 6, Table 6-1) applied at 25-percent TE for
all exterior steps;
2. The combination of coatings currently used by the coaters of
plastic parts applied at 40-percent TE for prime and color coats and
25-percent TE for texture and touch-up coats;
3. The use of organic-solvent-based coatings containing 50 percent,
by volume, solids at the spray gun applied at 25-percent TE for all
exterior coats (the quantity of plastic coated with waterborne coatings
remains at baseline levels);-
4. The use of organic-solvent-based coatings containing 50 percent,
by volume, solids at the spray gun applied at 40-percent TE for prime
and color coats and 25-percent TE for texture and touch-up coats;
5. The use of organic-solvent-based coatings containing 60 percent,
by volume, solids at the spray gun applied at 25-percent TE for all
1-2
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exterior coats (the quantity of plastic coated with waterborne coatings
remains at baseline levels);
6. The use of organic-solvent-based coatings containing 60 percent,
by volume, solids at the spray gun applied at 40-percent TE for prime
and color coats and 25-percent TE for texture and touch-up coats;
7. The use of waterborne coatings containing 37 percent, by volume,
solids at the spray gun and a VOC-to-water volume ratio of 1:4 in the
coating applied at 25-percent TE for all exterior coats; and
8. The use of waterborne coatings containing 37 percent, by volume,
solids at the spray gun and a VOC-to-water volume ratio of 1:4 in the
coating applied at 40-percent TE for prime and color coats and 25-percent
TE for texture and touch-up coats.
Exterior control option 1 represents the baseline. The EMI/RFI
control option and exterior control option used in each of the 32 regulatory
alternatives is presented in Table 1-1. Regulatory alternatives with
the suffix "-25" use the exterior options that require 25-percent TE for
all exterior steps (options 1, 3, 5, and 7). The alternatives with the
suffix "-25/40" use the exterior options that require 25-percent TE for
texture and touch-up coats and 40 percent TE for prime and color coats
(options 2, 4, 6, and 8).
1.2 ENVIRONMENTAL IMPACT
The beneficial and adverse environmental impacts that could result
from implementation of the 32 regulatory alternatives are summarized in
Table 1-2. The estimated effects in Table 1-2 were derived from the
detailed analyses of environmental and energy impacts of each regulatory
alternative presented in Chapter 7 relative to alternative 1-25, the
baseline.
The air impacts were ranked so that the alternatives with 0- to .
10-percent VOC emission reduction were rated at 0, those with reductions
between 11 and 15 percent were rated at +1, those between 16 and 35 percent
were rated at +2, those between 36 and 70 percent were rated at +3, and
those with greater than 70 percent emission reduction were rated at +4.
1-3
-------
Water quality is not expected to be affected adversely by any of
the first 16 alternatives in Table 1-1 (the "-25" alternatives) and is
slightly improved by the second 16 alternatives (the "-25/40" alter-
natives) because the coating overspray is reduced by the improved transfer
efficiency. The amount of solid waste generated would be slightly less
for all the alternatives that use zinc-arc spray as the EMI/RFI shielding
option compared to the amount for the alternatives that use metal-filled
coatings because the oversprayed zinc can be recovered and resold. The
"-25/40" alternatives produce a solid waste impact that is more beneficial
than the "-25" alternatives because of the reduced volume of coating
overspray.
Regulatory alternatives that use either waterborne exterior coatings
(for EMI/RFI shielding or exterior coating) or zinc-arc spray would
increase negligibly the energy required for the coating process. Compared
to organic-solvent-based coatings, waterborne coatings may require
additional time in an oven to speed up the drying process. Zinc-arc
spraying requires the use of an electric arc spray gun to melt and spray
the zinc wire. The zinc-arc spraying process is also noisy; therefore,
in-plant noise levels will be higher for alternatives using zinc-arc
spray.
1.3 ECONOMIC IMPACT
The economic impacts of each of the regulatory alternatives are
presented in Table 1-2. The economic impact ratings in Table 1-2 are
based on the total cost for the plastic parts coating industry presented
in Chapter 9, Table 9-15. According to Table 9-15, regulatory alter-
native VIII-25/40 is the most economically beneficial. For regulatory
alternative VIII-25/40, it is estimated in Table 9-7 that the capital
cost of a new facility will increase from the current, or baseline, cost
of $42,000 to $53,000 for small plants, from $476,000 to $497,000 for
medium plants, and from $956,000 to $992,000 for large plants. However,
according to Tables 8-7, 8-8, and 8-9, the annualized costs to each of
the three types of plants are expected to decrease. The annualized cost
should drop from the baseline cost of $434,000 to $327,000 for small
plants, from $2,665,000 to $2,327,000 for medium plants, and from
$5,667,000 to $4,983,000 for large plants.
1-4
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1-5
-------
TABLE 1-2. MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS
OF REGULATORY ALTERNATIVES
Regulatory
Alternative
1-25
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
XIII-25
XIV-25
XV-25
XVI-25
1-25/40
11-25/40
111-25/40
IV- 25/40
V-25/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40
X-25/40
XI-25/40
XII-25/40
XI 11-25/40
XIV-25/40
Ai r**
0
+1
+2
+2
+2 .
+3
+3
+3
+3
+3
+3
+3
+3
+4
+4
+4
+1
+2
+2
+3
+3
+3
+3
+3
+3
+3
+4
+3
+4
+4
Solid
Water* Waste*
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
+1
+1
+1
+1
+1
+1
+1
+1
+1 '
+1
+1
+1
+1
+1
0
0
0
+1
0
0
0
0
+1
0
0
0
+1
0
0
+1
+2
+2
+2
+2
+2
+2
+2
+2
+2
+2
+2
+2
+2
+2
Energy***
0
0
-1
-1
0
0
-1
0
0
0
-1
-1
0
-1
-1
-1
0
0
-1
0
0
0
-1
0
0
0
-1
-1
0
-1
Noise*
0
0
0
-2
0
0
0
0
-2
0
0
0
-2
0
0
-2
0
0
0
-2
0
0
0
0
-2
0
0
0
-2
0
Economic*
0
-2
-1
-2
+1
-2
-1
+4
-2
+3
+3
0
-2
-2
-1
-2
+3
+2
+3
— 9
+3
+2
+3
+4
-1
+4
+4
+3
+1
+2
(continued)
1-6
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TABLE 1-2. (continued)
Regulatory
Alternative
XV-25/40
XVI-25/40
Delayed Standard
Air**
+4
+4
0
Water*
+1
+1
0
Solid
Waste*
+2
+2
0
Energy***
-1
-1
0
Noise*
0
-2
0
Economic*
+2
-2
0
Key: - = Adverse impact
= Beneficial impact
= Short term impact
= Long term impact
= Irreversible impact
= No impact
= Negligible impact
= Small impact
= Moderate impact
= Large impact
*
**
***
0
1
2
3
4
1-7
-------
Regulatory alternative VII1-25/40 would decrease the cost of coating
plastic business machine parts by $83 million in 1990 and increase
employment in this industry by 4.16 percent. Detailed analyses of the
costs and economic impacts of the regulatory alternatives are presented
in Chapters 8 and 9.
1-8
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2. INTRODUCTION

2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different techno-
logies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for
a standard. The alternatives are investigated in terms of their impacts
on the economics and well-being of the industry, the impacts on the
national economy, and the impacts on the environment. This chapter sum-
marizes the types of information obtained by EPA through these studies
in the development of the proposed standards.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereafter referred to as the Act. Section 111 directs the Administrator
to establish standards of performance for any category of new stationary
source of air pollution which ". . . causes, or contributes significantly
to air pollution which may reasonably be anticipated to endanger public
health or welfare."
The Act requires that standards of performance for stationary
sources reflect "... the degree of emi'ssion limitation and the percentage
reduction achievable through application of the best technological
system of continuous emission reduction which (taking into consideration
the cost of achieving such emission reduction, any nonair quality health
and environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated." The standards apply only
2-1
-------
to stationary sources, the construction or modification of which
commences after the standards are proposed in the Federal Register.
The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
Examples of the effects of the 1977 amendments are:
1. The EPA is required to review the standards of performance
every 4 years and, if appropriate, revise them.
2. The EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures when a standard
based on emission levels is not feasible.
3. The term "standards of performance" is redefined, and a new
term "technological system of continuous emission reduction" is defined.
The new definitions clarify that the control system must be continuous
and may include a low- or non-polluting process or operation.
4. The time between the proposal and promulgation of a standard
under Section 111 of the Act may be extended to 90 days.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction,
taking into consideration the cost of achieving such emission reduction,
any nonair quality health and environmental impact and energy requirements.
Congress had several reasons for including these requirements.
First, standards having a degree of uniformity are needed to avoid
situations where some States may attract industries by relaxing standards
relative to other States. Second, stringent standards may help achieve
long-term cost savings by avoiding the need for more expensive retrofitting
when pollution ceilings may be reduced in the future. Third, certain
types of standards for coal-burning sources can adversely affect the
coal market by driving up the price of low-sulfur coal or by effectively
excluding certain coals from the reserve base due to their high untreated
pollution potentials. Congress does not intend that new source performance
standards contribute to these problems. Fourth, the standard-setting
process should create incentives for improving technology.
2-2
-------
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under
Section 111 or than those necessary to attain or maintain the National
Ambient Air Quality Standards (NAAQS) under Section 110. Thus, new
sources may in some cases be subject to State limitations that are more
stringent than standards of performance under Section 111, and prospective
owners and operators of new sources should be aware of this possibility
in planning for such facilities.
A similar situation may arise when a major emitting facility is to
be constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the
Act. These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term "best available control technology"
(BACT), as defined in the Act, means
... an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under this
Act emitted from or which results from any major emitting
facility, which the permitting authority, on a case-by-case
basis, taking into account energy, environmental, and economic
impacts and other costs, determines is achievable for such
facility through application of production, processes and
available methods, systems, and techniques, including fuel
cleaning or treatment or innovative fuel combustion techniques
for control of each such pollutant. In no event shall
application of "best available control technology" result in
emissions of any pollutants which will exceed the emissions
allowed by any applicable standard established pursuant to
Section 111 or 112 of this Act. (Section 169(3))
Although standards of performance are normally.structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases, physical measurement of emissions
from a new source may be impractical or exorbitantly expensive.
Section lll(h) provides that the Administrator may promulgate a design
or equipment standard in those cases where it is not feasible to prescribe
or enforce a standard of performance. For example, emissions of hydro-
carbons from storage vessels for petroleum liquids are greatest during
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tank filling. The nature of the emissions (i.e., high concentrations
for short periods during filling and low concentrations for longer
periods during storage) and the configuration of storage tanks make
direct emission measurement impractical. Therefore, a more practical
approach to standards of performance for storage vessels has been equip-
ment specification.
In addition, under Section lll(j) the Administrator may, with the
consent of the Governor of the State in which a source is to be located,
grant a waiver of compliance to permit the source to use an innovative
technological system or systems of continuous emission reduction. To
grant the waiver, the Administrator must find that: (1) the proposed
system has not been adequately demonstrated, (2) the proposed system
will operate effectively and there is a substantial likelihood that the
system will achieve greater emission reductions than the otherwise
applicable standards require or at least an equivalent reduction at
lower economic, energy, or nonair quality environmental cost, (3) the
proposed system will not cause or contribute to an unreasonable risk to
public health, welfare, or safety, and (4) the waiver, when combined
with other similar waivers, will not exceed the number necessary to
achieve conditions (2) and (3) above. A waiver may have conditions
attached to ensure the source will not prevent attainment of any NAAQS.
Any such condition will be treated as a performance standard. Finally,
waivers have definite end dates and may be terminated earlier if the
conditions are not met or if the system fails to perform as expected.
In such a case, the source may be given up to 3 years to meet the standards
and a mandatory compliance schedule will be imposed.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Administrator to list categories
of stationary sources. The Administrator ". . . shall include a category
of sources in such list if in his judgment it causes, or contributes
significantly to air pollution which may reasonably be anticipated to
endanger public health or welfare." Proposal and promulgation of
standards of performance are to follow.
2-4
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Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of an approach for assigning
priorities to various source categories. The approach specifies areas
of interest by considering the broad strategy of the Agency for impfle-
menting the Clean Air Act. Often, these areas concern pollutants that
are emitted by stationary sources rather than the stationary sources
themselves. Source categories that emit these pollutants were evaluated
and ranked considering such factors as: (1) the level of emission control
(if any) already required by State regulations, (2) estimated levels of
control that might be required from standards of performance for the
source category, (3) projections of growth and replacement of existing
facilities for the source category, and (4) the estimated incremental
amount of air pollution that could be prevented in a preselected future
year by standards of performance for the source category. Sources for
which new source performance standards were promulgated or which were
under development before or during 1977, were selected using these .
criteria.
The Act amendments of August 1977 establish specific criteria.to be
used in determining priorities for all source categories not yet 1/isted
by EPA. These are: (1) the quantity of air pollutant emissions which
each such category will emit, or will be designed to emit, (2) the
extent to which each such pollutant may reasonably be anticipated^to
endanger public health or welfare, and (3) the mobility and competitive
nature of each such category of sources and the consequent need for
nationally applicable new source performance standards. The Administrator
is to promulgate standards for these categories according to the schedule
referred to earlier.
In some cases, it may not be immediately feasible to develop
standards for a source category with a high priority. This might happen
if a program of research is needed to develop control techniques or if
techniques for sampling and measuring emissions require refinement] In
the development of standards, differences in the time required to complete
the necessary investigation for different source categories must also be
considered. For example, substantially more time may be necessary if
numerous pollutants must be investigated from a single source category.
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Further, the schedule for completion of a standard may change late in
the development process. For example, inability to obtatin emission data
from well-controlled sources in time to pursue the development process
in a systematic fashion may force a change in scheduling; Nevertheless,
priority ranking is, and will continue to be, used to establish the
order in which projects are initiated and resources are assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined. A source category may have several facilities that cause
air pollution, and emissions from these facilities may vary according to
magnitude and control cost. Economic studies of the source category and
of applicable control technology may show that air pollution control is
better served by applying standards to the more severe pollution sources.
For this reason, and because there is no adequately demonstrated system
for controlling emissions from certain facilities, standards often do
not apply to all facilities at a source. For the same reasons, the
standards may not apply to all air pollutants emitted. Thus, although a
source category may be selected to be covered by standards of performance,
not all pollutants or facilities within that source category may be
covered by the standards.
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must: (1) realistically reflect best
demonstrated control practice, (2) adequately consider the cost, the
nonair quality health and environmental impacts, and the energy require-
ments of such control, (3) be applicable to existing sources that are
modified or reconstructed as well as to new installations, and (4) meet
these conditions for all variations of operating conditions being
considered anywhere in the country.
The objective of a program for development of standards is to
identify the best technological system of continuous emission reduction
that has been adequately demonstrated. The standard-setting process
involves three principal phases of activity: (1) information gathering,
(2) analysis of the information, and (3) development of the standards of
performance.
2-6
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During the information gathering phase, industries are questioned
through telephone surveys, letters of inquiry, and plant visits by EPA
representatives. Information is also gathered from other sources,
including a literature search. Based on the information acquired about
the industry, EPA selects certain plants at which emission tests are
conducted to provide reliable data that characterize the pollutant
emissions from well-controlled existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory alter-
natives are essentially different levels of emission control.
The EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the industry and on the national economy,
on the environment, and on energy consumption. From several alternatives,
EPA selects the single most plausible regulatory alternative as the
basis for standards of performance for the source category under study.
In the third phase of a project, the selected regulatory alternative
is translated into performance standards, which, in turn, are written in
the form of a Federal regulation. The Federal regulation, when applied
to newly constructed plants and to modified or reconstructed facilities,
will limit emissions to the levels indicated in the selected regulatory
alternative.
As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee. Industry representatives and other interested
parties also participate in these meetings.
The information acquired in the project is summarized in the back-
ground information document (BID). The BID, the proposed standards, and
a preamble explaining the standards are widely circulated to the industry
being considered for control, environmental groups, other government
agencies, and offices within EPA. Through this extensive review process,
2-7
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the points of view of expert reviewers are taken into consideration as
changes are made to the documentation.
A "proposal package" is assembled and sent through the offices of
EPA assistant administrators for concurrence before the proposed standards
are officially endorsed by the EPA Administrator. After being approved
by the EPA Administrator, the preamble and the proposed regulation are
published in the Federal Register.
The public is invited to participate in the standard-setting process
as part of the Federal Register announcement of the proposed regulation. •
The EPA invites written comments on the proposal and also holds a public
hearing to discuss the proposed standards with interested parties. All
public comments are summarized and incorporated into a second volume of
the BID. All information reviewed and generated in studies in support
of the standards of performance is available to the public in a "docket"
on file in Washington, D.C. Comments from the public are evaluated, and
the standards of performance may be altered in response to the comments.
The significant comments and the EPA's position on the issues
raised are included in the preamble of a promulgation package, which
also contains the draft of the final regulation. The regulation is then
subjected to another round of review and refinement until it is approved
by the EPA Administrator. After the Administrator signs the regulation,
it is published as a "final rule" in the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111 of
the Act. The assessment is required to contain an analysis of: (1) the
costs of compliance with the regulation, including the extent to which
the cost of compliance varies depending on the effective date of the
regulation and the development of less expensive or more efficient
methods of compliance, (2) the potential inflationary and recessionary
effects of the regulation, (3) the effects the regulation might have on
small business with respect to competition, (4) the effects of the
regulation on consumer costs, and (5) the effects of the regulation on
2-8
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energy use. Section 317 requires that the economic impact assessment be
j
as extensive as practicable.
The economic impact of proposed standards upon an industry is
usually addressed both im absolute terms and by comparison with the
control costs that would be incurred as a result of compliance with
typical, existing State control regulations. An incremental approach is
taken because both new and existing plants would be required to comply
with State regulations in the absence of Federal standards of perfor-
mance. This approach requires a detailed analysis of the economic
impact of the cost differential that would exist between proposed standards
of performance and typical State standards.
Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal problem.
The total environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
A thorough study of the profitability and price-setting mechanisms
of the industry is essential to the analysis so that an accurate estimate
of potential adverse economic impacts can be made for proposed standards.
It is also essential to know the capital requirements for pollution
control systems already placed on plants so that the additional capital
requirements necessitated by these Federal standards can be placed in
proper perspective. Finally, it is necessary to assess the availability
of capital to provide the additional control equipment needed to meet
the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires Federal agencies to prepare detailed environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting the quality of the human environment.
The objective of NEPA is ;to build into the decision-making process of
Federal agencies a careful consideration of all environmental aspects of
proposed actions.
In a number of legal challenges to standards of performance for
various industries, the United States Court of Appeals for the District
2-9
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of Columbia Circuit.has held that environmental impact statements need
not be prepared by the Agency for proposed actions under Section 111 of
the Clean Air Act. Essentially, the Court of Appeals has determined
that the best system of emission reduction requires the Administrator to
take into account counterproductive environmental effects of proposed
standards, as well as economic costs to the industry. On this basis,
therefore, the Courts established a narrow exemption from NEPA for EPA
determinations under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the
quality of the human environment within the meaning of the National
Environmental Policy Act of 1969." (15 U.S.C. 793(c)(l))
Nevertheless, the Agency has concluded that the preparation of
environmental impact statements could have beneficial effects on certain
regulatory actions. Consequently, although not legally required to do
so by Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory
actions, including standards of performance developed under Section 111
of the Act. This voluntary preparation of environmental impact statements,
however, in no way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section is included in this
document that is devoted solely to an analysis of the potential environ-
mental impacts associated with the proposed standards. Both adverse and
beneficial impacts in such areas as air and water pollution, increased
solid waste disposal, and increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..."
after the proposed standards are published. An existing source is
redefined as a new source if "modified" or "reconstructed" as defined in
amendments to the General Provisions (40 CFR Part 60, Subpart A),
2-10
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which were promulgated in the Federal Register on December 16, 1975
(40 FR 58416).
Promulgation of standards of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standards for new sources limit emissions
of a designated pollutant (i.e., a pollutant for which air quality
criteria have not been issued under Section 108 or which has not been
listed as a hazardous pollutant under Section 112). If a State does not
act, EPA must establish such standards. General procedures for control
of existing sources under Section lll(d) were promulgated on November 17,
1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7 REVISION OF EXISTING STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise ..." the
standards. Revisions are made to ensure that the standards continue to
reflect the best systems of emission reduction that become available in
the future. Such revisions will not be retroactive but will apply to
stationary sources constructed or modified after the proposal of the
revised standards.
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3. THE SURFACE COATING OF PLASTIC PARTS FOR BUSINESS MACHINES:
PROCESSES AND POLLUTANT EMISSIONS

3.1 GENERAL
There are several industries that surface coat plastic parts for
business machines: the business machine manufacturing industry (SIC 3573,
3574, and 3579); the plastic parts molding industry (SIC 3079); and the
coating, engraving, and allied services industries (SIC 3471 and 3479).1
Although some coating is done during repair and reconditioning of such
machines, this is done in dispersed locations and at low volumes and has
not been studied in the development of this document. Resin suppliers
(SIC 2821), industrial coatings suppliers (SIC 2851), and coating equipment
vendors (SIC 3564) supply the materials and equipment used to surface-coat
plastic parts.1 They interact with the molders and coaters of plastic
parts and contribute significantly to research and development of new
coating materials and processes.
Figure 3-1 illustrates the relationships among the industrial
sectors involved in production of surface-coated plastic parts for busi-
ness machines. One source estimates that over 3,000 facilities nationwide
perform coating of plastic parts for business machines.2 Plastic parts
may be molded and coated in-house by business machine manufacturers;
however, the molding and the coating of parts are frequently contracted
out to other companies that specialize in these processes. The molding
and coating steps may be performed by separate companies, or both steps
may be performed at a single plant. Regardless of who actually performs
the coating step, the finish quality (i.e., color, gloss, adhesion,
chemical resistance, abrasion resistance, etc.) is specified by the
business machine manufacturer. Business machine'manufacturers usually
specify one or more coatings that are acceptable for contract coaters to -
3-1
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VOC EMISSIONS
MOLDED
PARTS
CONTRACT
OR IN-HOUSE
COATING
OPERATIONS
COATINGS
CONTRACT
OR IN-HOUSE
HOLDING
OPERATIONS
COATED [I
PARTS T T
BUSINESS
MACHINE
MANUFACTURING
COMPANIES
COATING
MANUFACTURERS
RESINS
FOR PARTS
RESIN
MANUFACTURERS
RESINS
FOR COATINGS
Figure 3-1. Relationship among industrial sectors involved in the
surface coating of plastic parts for business machines.
3-2
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use. Both organic-solvent-based coatings and waterborne coatings may be
specified for application to plastic business machine parts. Although
waterborne coatings use water as their primary solvent, they also contain
some organic solvents. Volatile organic compounds (VOC) are emitted to
the atmosphere during the coating and curing processes when organic
solvents and other volatile organic components evaporate from the coatings.
Resins that are commonly used to produce plastic business machine
parts include acrylonitrile-butadiene-styrene (ABS), polycarbonate (PC),
polyphenylene oxide (PRO), polystyrene (PS), and polyurethane (PU).3-13
Various other plastics such as polypropylene (PP) and fiberglass rein-
forced sheet molding compound (SMC) are used less frequently.6-14
3.2 FACTORS INFLUENCING SURFACE COATING OF PLASTIC PARTS
Plastic parts for business machines are coated for three major
reasons: (1) to improve their appearance; (2) to protect the plastic
part from physical and chemical stress; and (3) to attenuate electro-
magnetic interference/radio .frequency interference (EMI/RFI) signals
that would otherwise pass through plastic housings.
3.2.1 Factors Influencing Exterior Coating
3.2.1.1 Molding Techniques. The need to apply decorative coatings
to plastic parts to improve their appearance and to meet manufacturer
and buyer preferences is determined to a large extent by the molding
techniques employed. Structural foam injection molding and straight
injection molding are the two predominant forming techniques, although
some compression molding and reaction injection molding (RIM) of plastic
parts is performed.14 Each accounts for slightly less than 50 percent
of plastic business machine housing production.14 Structural foam
injection molding produces parts with surface flaws that require sub-
stantial surface coating, whereas, straight injection molding can produce
parts with molded-in color and texture that require little or no decorative
surface coating.4,5,15-18 It follows that finishing costs, when considered
alone, favor the use of straight injection molding. However, tooling
for structural foam molds costs from one-third to two-thirds less than
for injection molds.15,19 Therefore, molding costs favor the use of
structural foam injection molding, especially for large, complex-shaped
parts.
3-3
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3.2.1.2 Other Factors Influencing Exterior Coating. Plastic parts
are often coated to match the color and texture of metal parts or other
plastic parts. Color matching is often difficult to achieve with molded-
in color; however, only a small percentage of straight-injection-molded
parts receive decorative exterior coatings. Color reproducibility and
color stability of plastic parts are generally more easily controlled by
coating the parts than by using molded-in color.5,18,20-21
The surface characteristics of the molded part and, therefore, the
amount of surface finishing required for a part are influenced by the
design of the part, the design of the mold, and molding parameters such
as injection rate, molding temperature, and injection pressure.22 Many
surface flaws that require sanding, filling, and application of coatings
that emit VOC can be minimized by close interaction among the business
machine part designers, molding and coating line personnel, and the
suppliers of equipment and materials.22 Reducing the number and the
severity of surface flaws can reduce the total film thickness of coating
necessary to hide them.
In addition to improving the appearance of plastic parts, coatings
can protect the parts from various environmental stresses. The specific
end use of the parts determines which of the following physical character-
istics is most critical: color, gloss, adhesion, pencil hardness,
impact resistance, flexibility, abrasion resistance, ultraviolet (UV)
light stability, salt resistance, and solvent resistance. For instance,
an office copying machine should have a durable finish that is resistant
to abrasion because the machine is used frequently. On the other hand,
durability may not be as critical for the finish on a desktop computer
housing as color and gloss may be.23 Some business machine manufacturers
perform laboratory tests that measure these characteristics for different
coatings. The outcome of the tests influences the particular coating(s)
they specify for application to their products.24
3.2.2 Physical and Chemical Limitations of Plastics
The properties of the plastics used to make business machine parts
determine the types of coatings that can be used. Some plastics are
damaged by organic solvents present in organic-solvent-based and water-
borne coatings. Another important property of plastic parts is their
3-4
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tendency to deform at temperatures normally used to cure coatings on
metal parts. Coatings on plastic parts are typically cured at
temperatures of 60°C (140°F) or less, whereas many coatings used on
metal parts are cured at temperatures exceeding 93°C (200°F).7-13,25,26
For this reason, many coatings used on metal cannot be used on plastic.
3.2.3 Factors Influencing EMI/RFI Shielding
Unlike metal business machine housings, which are conductive,
plastic housings allow the passage of EMI/RFI signals that are emitted
from the enclosed electronic components. The EMI/RFI signals emitted
from business machines can interfere with the performance of other
electronic devices such as radios and televisions. Conversely, EMI/RFI
signals from outside sources can interfere with performance of the
electronic components within an unshielded plastic business machine
housing. The increased use of plastics for business machine housings
and the increase in circuit density afforded by advances in circuit
technology have resulted in a corresponding increase in EMI/RFI inter-
ruption of the airwaves.2^ To combat EMI/RFI propagation, the Federal
Communications Commission (FCC) has regulated EMI/RFI emissions from
computing devices.28 The limitations for the electric field strength
from computing devices, which are outlined in Table 3-1, have caused a
rapid increase in the use of EMI/RFI shielding materials.29
The two major performance specifications for EMI/RFI shielding
materials are conductivity and adhesion. Conductivity is required for
both EMI/RFI shielding and electrostatic discharge (ESD) protection.
The EMI/RFI signals are best shielded with grounded, high conductivity
coatings. These coatings usually have a surface resistance of less than
1 ohm per square. However, ESD protection is best achieved with
grounded, low conductivity coatings with surface resistance of 2 to
20 ohms per square. Although a high conductivity surface may prevent a
spark from reaching internal electronic components in one area of a
housing, the spark may arc to the internal components in another area as
it travels directly to the grounding connection. A low conductivity
surface spreads the energy over a larger area as it travels to ground,
preventing a build-up of localized charge.30
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TABLE 3-1. EMI/RFI RADIATION LIMITS ESTABLISHED BY THE FCC28
Class .A Computing Devices9 Class B Computing Devices
Frequency, MHz uV/m , measured at 30 m uV/m, measured at 30 m
30-88
88-216
216-1000
30
50
70
100
150
200
Class A devices are defined in Section 15.4(o) of the FCC Rules [47 CFR
15.4(o)] as computing devices marketed for use in a commercial,
•industrial, or'business environment.
DClass B devices are defined in Section 15.4(p) of the FCC Rules [47 CFR
15.4(p)] as computing devices marketed for use in a residential environ-
ment notwithstanding use in a commercial, industrial, or business environ-
ment.
JMHz = megahertz.
uV/m = microvolts/meter.
m = meter.
3-6
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Adhesion is measured by a procedure developed by Underwriters
Laboratories, Incorporated (UL). Test panels of coated plastic are
subjected to high temperature, high temperature and humidity, and
thermal cycling, and then evaluated according to how well the coating
adheres to the plastic. Coatings that pass these tests are listed with
UL and are considered to be safe from the risk of electrical shock,
fire, or personal injury.31-33
3.3 PROCESSES OR FACILITIES AND THEIR EMISSIONS
Surface coating processes for plastic parts used in business
machines fall into two categories: coating processes that provide
EMI/RFI shielding and coating processes that provide
decorative/protective finishes. Figure 3-2 illustrates the two major
divisions of coating processes and the general steps involved in each
process. Not all plastic parts undergo both coating processes. For
example, a plastic business machine housing with satisfactory molded-in
color and texture may require an EMI/RFI shielding coating, but not a
decorative/protective coating. Similarly, not all plastic parts that
receive decorative/ protective coatings require EMI/RFI shielding. If
both processes are required, EMI/RFI shielding is normally done first.
3.3.1 Coating Application Methods
Coatings are spray applied in this industry. Other coating
techniques such as flow coating and dip coating may be used infrequently
for specialized, low volume applications. In all spray coating
operations, some coating solids are wasted because they either miss or
bounce off the part. Coating solids that do not adhere to the part are
called overspray. Transfer efficiency is the ratio of the amount of
coating solids deposited on a surface to the total amount of coating
solids sprayed.
3.3.1.1 Spray Systems. The three basic spray methods used in this
industry are air atomized spray, air-assisted airless spray, and
electrostatic air spray. Air atomized spray is the most widely used
coating technique for plastic business machine parts.4,7-13
Air-assisted airless spray is growing in popularity but is still not
frequently used.4,7-13 Electrostatic air spray is only rarely used
3-7
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\
^10LDED
PART f
/
EMI/RFI
SHIELDING
PROCESS
SURFACE
PREPARATION
METAL-
FILLED
COATINGS
/FINISHED^
PART /
DECORATIVE/
PROTECTIVE
EXTERIOR
COATING PROCESS
\ r
SURFACE
PREPARATION
Figure 3-2. Coating processes for plastic parts used in business machines,

3-8 .
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because plastic parts are not conductive; however, it has been
demonstrated for parts which have first been treated with a conductive
sensitizer or plated with a thin film of metal.34-37
Air atomized spray coating uses compressed air, which may be heated
and filtered, to atomize the coating and to direct the spray. Air
atomized spray equipment is compatible with all coatings that are commonly
used on plastic parts for business machines. Although transfer effi-
ciencies vary depending upon the shape of the target, the type of coating
used, and other factors, they tend to be lower with this method than
with other application methods.4 Transfer efficiencies for air atomized
spray have been estimated to be over 50 percent in some cases and as low
as 15 percent in others.4,7-13,19,38-48 Based on the available informa-
tion, the average transfer efficiency for air atomized spray has been
estimated to be about 25 percent for exterior coatings and about 50 percent
for EMI/RFI shielding coatings. The higher transfer efficiency for
EMI/RFI shielding is the result of two major factors. First, the pressure
at the spray gun is less for EMI/RFI shielding, which reduces the degree
of coating bounceback. Bounceback occurs when the coating from the gun
encounters a barrier of compressed air and entrained coating that is
moving away from the surface of the part. Second, EMI/RFI shielding
coatings are usually applied to the interior surface of a cabinet or
housing, so coating that may bounce off one wall will likely encounter
another wall.
Air-assisted airless spray is a variation of airless spray, a spray
technique used in o-ther industries. In airless spray coating, the
coating is atomized without air by forcing the liquid coating through
specially designed nozzles, usually at pressures of 7 to 21 Megapascals
(MPa) (1,000 to 3,000 psi).49 Air-assisted airless spray atomizes the
coating by the same mechanism as airless spray, but at lower fluid
pressures (<7 mPa).50 A small amount of air is used to further atomize
the coating and to help shape the spray pattern, reducing the amount of
overspray below that achieved with airless atomization alone.50 The
transfer efficiency of air-assisted airless spray guns is discussed in
Chapter 4.
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In electrostatic air spray, usually the coating is charged and the
parts being coated are grounded to create an electric potential between
the coating and the parts. The atomized coating is attracted to the
part by electrostatic force. Because plastic is an insulator, it is
necessary to provide a conductive surface that can bleed off the elec-
trical charge to maintain the ground potential of the part as the charged
coating particles accumulate on the surface.38 Conductivity of the
plastic surface can be achieved by deposition of a thin metal film onto
the surface of the plastic part or by application of a conductive sensitizer
onto the part. These are the only two methods that have been used
successfully in production for electrostatic air spray coating of plastic
parts used in business machines.34-36 Other methods that have been used
to coat plastic parts electrostatically include the use of conductive
(waterborne) coatings and the placement of a grounded metal image behind
the part being coated.37,38,51,52 No one is known to use these methods
for production coating of plastic business machine parts. Transfer
efficiencies for electrostatic air spray coating of plastic parts are
discussed in Chapter 4.
3.3.2 EMI/RFI Shielding Processes
EMI/RFI shielding is done in a variety of ways. The relative use
of each is as follows: about 45 percent is done by zinc-arc spraying, a
process which does not emit VOC; approximately 45 percent is accomplished
using organic-solvent-based and waterborne metal-filled coatings; and
the remaining EMI/RFI shielding is achieved by a variety of techniques
that include electroless plating, the use of conductive plastics, the
use of metal inserts, vacuum metallizing, and sputtering.29,40,53 These
processes are described in the following sections.
3.3.2.1 Zinc-Arc Spray. Zinc-arc spraying is a two-step process
in which the plastic surface (usually the interior of a housing) is
first roughened by sanding or grit-blasting, and then spray-coated with
molten zinc. Both the surface preparation and the zinc-arc spraying
steps are currently performed manually; however, robot-operated systems
have recently become available.54,55
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Zinc-arc spraying requires a spray booth, a special spray gun,
pressurized air, and zinc wire. The process generates noise and smoke;
therefore, protective equipment for the operators is necessary. Intense
light is also generated.54-56
The zinc-arc spray gun operates by mechanically feeding two zinc
wires into the tip of the spray gun, where they are melted by an electric
arc. A high-pressure air nozzle blows the molten zinc particles onto the
surface of the plastic part. A zinc coating thickness ranging from 1 to
4 mils (1 mil = .001 inch) is common, depending upon shielding require-
ments. 56
3.3.2.2 Spray Application of Conductive Coatings. Both
organic-solvent-based and waterborne coatings are being used for EMI/RFI
shielding. Organic-solvent-based conductive coatings contain particles
of nickel, silver, copper, or graphite, in either an acrylic or urethane
resin. Nickel-filled acrylic coatings are the most frequently used
because of their shielding ability and cost.4,57,58 Nickel-filled
urethane coatings are more expensive than nickel-filled acrylic
coatings, but are reported to give a more durable finish.4,57,58
Nickel-filled acrylics and urethanes that contain from 15 to 25 percent,
by volume, solids at the gun (i.e., at the point of application or as
applied) are being used to coat plastic business machine parts.7-13
Waterborne. nickel-filled acrylics containing between 25 and
34 percent, by volume, solids at the gun (approximately 50 to 60 percent,
by volume, solids, minus water) are being used less frequently than
organic-solvent-based conductive coatings. These waterborne conductive
coatings contain approximately 0.23 to 0.47 kg VOC/2 of coating (1.9 to
3.9 Ib VOC/gal of coating), minus water.59-61 Some coaters feel that
waterborne conductive coatings do not adhere as well to plastic as do
organic-solvent-based conductive coatings, but there are at least two
waterbornes that are UL-approved for adhesion.62
Conductive coatings can be applied with most conventional spray
equipment. They are usually applied manually with air spray guns,
although air-assisted airless spray guns are sometimes used. Electro-
static spray methods cannot be used because of the high conductivity of
the EMI/RFI shielding coatings.37 Because of the density of metal
3-11
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particles, paint pots with agitators are used to prevent the particles
from settling prior to application.20,58,63
The coating process usually involves three steps: surface
preparation, coating application, and curing. Although the first step
can be eliminated if the parts are kept free of mold-release agents and
dirt, part surfaces are usually cleaned by wiping with organic solvents
or detergent solutions and roughened by light sanding.58 The coatings
are usually applied to the interior surface of plastic housings at a dry
film thickness of 1 to 3 mils.7-13 Most conductive coatings can be
cured at room temperature, but some must be baked in an oven.
3.3.2.3 Other EMI/RFI Shielding Methods. Other EMI/RFI shielding
processes include electro!ess plating, vacuum metallizing, sputtering,
the use of conductive plastics, and the use of metal inserts. None of
these techniques represent a significant portion of the EMI/RFI shielding
market at the present time.29
Electroless plating is a dip process in which a film of metal is
deposited from aqueous solution onto all, exposed surfaces of the part.
In the case of plastic business machine housings, both sides of the
housing are coated. No VOC emissions are associated with the plating
process itself. However, coatings that emit VOC's may be applied prior
to the plating step so that only selected areas of the parts are plated.64
Water treatment may be necessary when the electro!ess plating process is
used.
Vacuum metallizing and sputtering are similar techniques in which a
thin film of metal (usually aluminum) is deposited from the vapor phase
onto the plastic part. Although no VOC emissions occur during the
actual metallizing process, VOC-emitting prime coats that ensure good
adhesion and top coats that protect the metal film are often applied.
Conductive plastics are thermoplastic resins that contain conductive
flakes or fibers composed of materials such as aluminum, steel, metallized
glass, or carbon. Resin types that are available with conductive fillers
include ABS, ABS/PC blends, PRO, nylon 6/6, polyvinyl chloride, and
polybutyl terephthalate.27,65,66 The conductivity and, therefore, the
EMI/RFI shielding effectiveness of- these materials relies on contact or
close proximity between the conductive particles within the resin
3-12
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matrix.65,66 Conductive plastic parts are usually formed by straight
injection molding.66 Structural foam injection molding can reduce the
EMI/RFI shielding effectiveness of these materials because air pockets
within the structural foam separate the conductive particles.66
3.3.3 Coating of Parts for Decorative/Protective Purposes
3.3.3.1 The Coating Process. The general process for spray coating
of parts was shown in Figure 3-2. The three basic steps in the process
are surface preparation, spray coating, and curing. Each step may be
repeated several times for a given part.
The surface preparation step may, involve merely wiping off the
surface or may involve sanding and puttying to smooth the surface.
Parts are spray-coated in partially enclosed booths. An induced air
flow is maintained through the booths to remove overspray and to keep
solvent concentrations at a safe level. Dry filters or water curtains
are used to remove overspray particles from the booth exhaust. Coatings
may be partially or completely cured at room temperature, but ovens are
usually employed to speed up the curing process.
Spray coating systems commonly used in this industry fall into
three categories: the three-coat system, the two-coat system, and the
single-coat system. The three-coat system is the most commonly used
coating system for structural foam parts.6 The three-coat system
consists of a prime coat, a color or base coat, and a texture coat.
Typical dry film thickness ranges from 1 to 3 mils for the prime coat
and is about 1 to 2 mils for the color coat.3,5,7-13 The texture coat
is a spatter coat consisting of discrete, raised spots of paint;
therefore, a true, continuous film thickness cannot be measured. An
effective film thickness of 1 to 5 mils, however, is frequently
estimated for the texture coat.3,5,7-13 The same coating is generally
used for the color coat and texture coat, but the texture coat is
applied at a lower atomization pressure and a higher viscosity. The
two-coat system employs a color or base coat and a texture coat.
Typical dry film thicknesses for the color coat and texture coat are
2 mils and 2 to 5 mils, respectively.7-13
3-13
-------
The single-coat system is not frequently used. This process
employs a low solids color coat to protect the plastic substrate or
improve color matching between parts with molded-in color and texture.18
Less coating solids are applied with the single-coat system than with
the other systems. The dry film thickness applied for the single-coat
system depends on the function of the coating. If protective properties
are desired, the dry film thickness must be at least 1 mil. For
purposes of color matching between parts with molded-in color and
texture, a dry film thickness of 0.5 mil or less is needed to avoid
masking the molded-in texture. The process of applying 0.5 mil or less
of coating solids for color matching is commonly known as "fog coating,"
"mist coating," or "uniforming."
A typical conveyorized coating line using the three-coat system is
depicted in Figure 3-3. The conveyorized line consists of three separate
spray booths, each followed by a flash-off area. The final flash-off
area is followed by a curing oven.
3.3.3.2 Organic-So1 vent-Based Coatings. The most frequently used
exterior coatings for plastic parts used in business machines are organic-
solvent-based two-component catalyzed urethanes. These coatings may
represent as much as 90 percent of the exterior decorative/protective
coatings currently being used on plastic parts for business machines.4,6,18
The isocyanate catalysts in these coatings allow them to cure at low
temperatures.
The most frequently used two-component urethanes contain roughly
30 to 35 percent, by volume, solids at the gun.4,6,18 Conventional air
atomized spray guns and paint pots can be used with these coatings.
Air-assisted airless and electrostatic air spray equipment can also be
used to apply these coatings. The pot life of the catalyzed urethanes
in this solids range is sufficiently long (approximately 8 hours) that
the coating and the catalyst can be pre-mixed.
Although they are not as common, urethanes containing between
40 and 54 percent, by volume, solids at the gun are being used routinely
by some coaters.4,6,18,67,68 Air atomized, air-assisted airless, and
electrostatic air spray equipment may be used with these coatings. The
pot life of these urethanes is approximately 1 to 4 hours once the
3-14
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coating and catalyst are mixed.4,18 The effective pot life can be
extended indefinitely by drawing the catalyst and coating from separate
reservoirs through a plural-component metering system, which mixes the
coating and the catalyst at or prior to the spray gun.
Urethanes containing more than 60 percent, by volume, solids at the
gun are currently experimental. Because these coatings cure in less
than 1 hour, the coating and catalyst are not usually mixed in the same
reservoir. Instead, they may require the use of plural-component metering
equipment with high-pressure pumps. These coatings were used briefly in
production to coat plastic parts for business machines; however, they
were reformulated at about 53 percent, by volume, solids at the gun to
extend their pot life without using plural component metering
equipment.2,63,68-72
Organic-solvent-based acrylic coatings are being used to a limited
extent on plastic business machine parts. These coatings are available
with solids contents of about 30 to 60 percent, by volume, at the gun;
however, coatings at the upper end of this range are still experimental.74-75
Unlike the two-component catalyzed urethanes, there are no pot-life
problems associated with single-component acrylics, although some of the
higher solids content acrylics are two-component coatings which require
the use of an oven bake to completely cure the coating.73 This additional
equipment expense has affected the marketing of the two-component acrylics
such that they remain experimental coatings.73
3.3.3.3 Waterborne Coatings. Waterborne coatings are routinely
used on plastic parts for business machines. Some manufacturers are
satisfied with the performance and the appearance of waterborne
coatings.76-78 Others feel that waterborne coatings do not have the
adhesion and resistance qualities that are obtained with organic-
solvent-based coatings.17,20,21 Both air atomized and air-assisted
airless spray equipment can be used to apply waterborne coatings.
Electrostatic air spray equipment can be used if the entire system is
isolated from grounded surfaces.37
Advantages of waterborne coatings are that they are less flammable
and less toxic because of the small amount of organic solvent present in
the coatings. Waterborne coatings have some disadvantages, such as
3-16
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increased rust of coating equipment compared to organic-solvent-based
coatings. Waterborne coatings do not exhibit the self-cleaning
(degreasing) ability that some organic-solvent-based coatings exhibit on
parts, which may lead to the need for greater expenditure of time and
money in the cleaning process. Waterborne coatings are also more expen-
sive, require longer cure times, and require higher atomization pressures
than organic-solvent-based coatings.6,79 However, some coating
manufacturers state that overall finishing costs of waterborne coatings
are less than or equal to the overall finishing costs of urethanes.80
The most commonly used waterborne coatings are waterborne acrylics,
which may represent as much as 10 percent of the coatings applied to
plastic parts for business machines. These coatings typically contain
no more than 37 percent, by volume, solids as applied (75 percent, by
volume, solids minus water). The VOC content of these coatings is
usually about 0.24 kg VOC/£ of coating (2 Ib VOC/gal of coating), minus
water, at the gun.3
An acid-catalyzed waterborne coating using a proprietary resin has
recently been introduced for use on business machine parts. This new
coating has a higher solids content (42 percent, by volume) than is
possible with waterborne acrylics.4,80 Its VOC content is estimated at
0.18 kg VOC/£ of coating (1.5 Ib VOC/gal of coating), minus water, at
the gun.78 The coating is reported to have good adhesion and resistance
properties on all plastics, comparing favorably with organic-solvent-based
urethanes.80
3.3.3.4 Powder Coatings. Powder coatings are not used on plastic
parts for business machines because they require curing temperatures
that exceed the temperature limitations of the plastic parts.81 Powder
coatings that can be cured with ultraviolet (UV) or infrared (IR) radiation
are being developed and, once proven, may be applicable to this industry.81
3.4 BASELINE EMISSIONS
The baseline emission level is the level of emission control that
would exist for the surface coating of plastic parts for business machines
in the absence of a new source performance standard (NSPS).
3-17
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3.4.1 Existing Emission Regulations
Because there are presently only one State regulation and two local
regulations specifically controlling VOC emissions from the surface
coating of plastic parts, the baseline emission level for this process
cannot be determined from State Implementation Plans (SIP's). Some
general solvent handling and surface coating regulations are used by
States to limit VOC emissions from the surface coating of plastic parts
for business machines, but the majority of States either do not regulate
this process or use construction and operating permits to limit emissions.
The State of Missouri and two air pollution control districts in
the State of California have proposed regulations that would limit the
VOC content of coatings used on plastic parts.82-84 Only one facility
is known to be affected by the Missouri regulation.83 This facility
does not coat business machine parts.
3.4.2 Coating Utilization
Because of the lack of State regulations controlling the surface
coating of plastic parts, the baseline emission level was determined
through the use of coating consumption data obtained from this industry.
Because no add-on emission control devices are used in this industry,
VOC emissions are a function of coating formulation and coating
consumption.
Information in the literature and from contacts with coaters of
plastic parts for business machines show that organic-solvent-based
coatings containing about 30 percent, by volume, solids as applied are
the most commonly used exterior coatings.4-13,18,41,42
Organic-solvent-based exterior coatings containing roughly 50 percent,
by volume, solids as applied are also being used.4-13,18,41,42
Organic-solvent-based nickel-filled acrylics containing about 15 percent,
by volume, solids as applied are the most commonly used organic EMI/RFI
shielding coatings.4-13,18,40 Altogether, organic-solvent-based coatings
represent at least 90 percent of the organic coatings applied to plastic
parts for business machines.4-13,18,41,42 The remaining 10 percent is
made up of waterborne coatings, most of which contain about 37 percent,
by volume, solids and about 13 percent, by volume, VOC as
applied.4-13,18,41,42
3-18
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Coating consumption data for typical plants appear in Table 3-2.
These data represent the baseline condition, or the coating consumption
that would be expected in the absence of an NSPS.
3-19
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TABLE 3-2. COATING UTILIZATION OF A TYPICAL PLANT
Type of coating
Solvent-based EMI/RFI
shielding coating
"Lower solids" solvent-
based coating
"Medium solids" solvent-
based coating
Waterborne coating
(water/VOC = 80/20)
Percent
solids,
by volume,
at the gun
15
32
50
37
Percent
of total
coating
consump-
tion
17.1
53.7
19.5
9.7
VOC
kg/a
coating
(Ib/gal of
coating
less water
0.75 (6.3)
0.60 (5.0)
0.44 (3.7)
0.22 (1.9)
content3
kg/a of
solids
(Ib/gal
of solids)
5.00 (42.0)
1.87 (15.6)
0.88 (7.3)
0.30 (2.5)
aAssum1ng an average solvent density of 0.882 kg/a (7.36 Ib/gal).
3-20
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3.5 REFERENCES FOR CHAPTER 3

1. Statistical Policy Division, Office of Management and Budget. Standard
Industrial Classification Manual. U.S. Government Printing Office.
Washington, D.C. 1972.

2. The Sherwin-Williams Company Chemical Coatings News. Issue No. 9.
Chicago, Illinois. Fall, 1983. pp. 1-2.

3. Memo from Glanville, J., MRI, to Salman, D., EPArCPB. September 7,
1983. Site Visit—Ex-Cell-0 Corp., Athens, Tennessee.

4. Telecon. Newton, D., MRI, with Von Hor, R., Ex-Cell-0 Corp. July 22,
1983. Coatings, processes, and trends in the surface coating of
plastic parts for business machines.

5. Memo from Hester, C., MRI, to Salman, D., EPArCPB. April 15, 1983.
Site Visit—Southeastern-Kusan, Inc., Inman, South Carolina.
6. Vacchiano, T. Painting Plastics for Business Machines.
Finishing. 45(5):62-66. February 1981.
Products
7. Letter and attachments from Harman, C. T., Cashiers Structural Foam
Division, Consolidated Metco, Inc., to Farmer, J., EPA. December 8,
1983. Response to Section 114 letter on the surface coating of
plastic parts for business machines.

8. Letter and attachments from Webb, J. W., Eastman-Kodak Company, to
Farmer, J., EPA. November 9, 1983. Response to Section 114 letter
on the surface coating of plastic parts for business machines.

9. Letter and attachments from Walker, D., Como Plastics, to Farmer, J.,
EPA. October 28, 1983. Response to Section 114 letter on the surface
coating of plastic parts for business machines.

10. Letter and attachments from Barlow, G. L., E/M Lubricants, Inc., to
Farmer, J., EPA. November 28, 1983. Response to Section 114 letter
on the surface coating of plastic parts for business machines.

11. Letter and attachments from Hall, D., Premix, Inc., to Farmer, J.,
EPA. October 4, 1983. Response to Section 114 letter on the surface
coating of plastic parts for business machines.

12. Letter and attachments from Brewer, W. S., NCR Corp., to Farmer, J.,
EPA. September 29, 1983. Response to Section 114 letter on the
surface coating of plastic parts for business machines.

13. Letter and attachments from Eisenga, L. C. , Leon Plastics, to
Farmer, J., EPA. November 1, 1983. Response to Section 114 letter
on the surface coating of plastic parts for business machines.
3-21
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14. Plastics in Business Machines Growing. Plastics World. 40:10.
July 1982.

15. Three Ways to Produce Desktop Computer Housing. Plastics World.
40:34-39. September 1982.
16. Forger, G. Apple Moves to Injection, Cuts Costs Over
Plastics World. 41:32-34. May 1983.
Million.
17. Telecon. Glanville, J., MRI, with Clockedile, A., Digital Equipment
Corp. July 14, 1983. Coatings, processes, and trends in the surface
coating of plastic parts for business machines.

18. Telecon. Newton, D., MRI, with Holt, R., Sherwin-Williams Company
July 15, 1983. Coatings, processes, and trends in the surface coating
of plastic parts for business machines.

19. Telecon. Newton, D., MRI, and D. Salman, EPA:CPB, with Wendle, B.,
Society of the Plastics Industry. September 7, 1984. Comments on
draft BID Chapters 3 through 6.

20. Telecon. Newton, D., MRI, with Bond, S., MDS-Qantel Corp. July 28,
1983. Coatings, processes, and trends in the surface coating of
plastic parts for business machines.

21. Telecon. Newton, D., MRI, with Harris, G., E.M.A.C., Inc. July 20,
1983. Coatings, processes, and trends in the surface coating of
plastic parts for business machines.

22. Carlisle, J. W. Resolving Plastic Finishing Problems . . . Before
They Occur. Bee Chemical Company. Lansing, Illinois. (Presented at
the Finishing '83 Conference sponsored by the Association for Finishing
Processes of the Society of Manufacturing Engineers. Cincinnati.
October 11-13, 1983.) 12 p.

23. Telecon. Duletsky, B., MRI, with Simmons, I., Eastman Kodak Company.
August 10, 1984. Information on coating structural foam and injection
molded parts.

24. Telecon. Duletsky, B., MRI, with Taub, L., Texas Instruments, Inc.
March 16, 1984. Trends in the surface coating of plastic parts.

25. Memo from Newton, D., MRI, to Salman, D., EPA:CPB. September 15,
1983. Site Visit—Finishing Technology, Inc., Santa Clara, California.

26. Surface Coating of Metal Furniture—Background Information for Proposed
Standards. U.S. Environmental Protection Agency. Research Triangle
Park, North Carolina. Publication No. EPA-450/3-80-007a.
September 1980. pp. 3-16, 3-22, and 3-33.
3-22
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27. Conductive Plastics. Chemical Week. 133(3):38-42. July 20, 1983.

28. Federal Communications Commission. Computing Devices Rules. 47 CFR,
Part 15, Subpart J. May 1981.

29. Ellis, J. R., and R. S. Schotland. Electrically Conductive Polymeric
Systems Market Outlook. Princeton Polymer Laboratories, Inc.,
Plainsboro, New Jersey, and Schotland Business Research, Inc.,
Princeton, New Jersey. (Presented at the 40th Annual Technical
Conference and Exhibition of the Society of Plastics Engineers. San
Francisco. May 10-13, 1982.) 3 p.

30. Telecon. Duletsky, B., MRI, with Lane, S., Acheson Colloids Company.
September 20, 1984. Information about organic-solvent-based conductive
coatings.

31. Telecon. Duletsky, B., MRI, with Yablonski, D., Underwriter's
Laboratory. September 25, 1984. Information on adhesion test for
conductive coatings.

32. Standard for Safety: Polymeric Materials—Use in Electrical Equipment
Evaluations. Underwriters Laboratories, Inc. March 25, 1983.
pp. 33-34B.

33. Telecon. Duletsky, B., MRI, with Harris, B., Acme Chemical Company.
September 24, 1984. Information on organic-solvent-based conductive
coatings.

34. Poll, G. H., Jr. Programmed Painting at Texas Instruments. Products
Finishing. 47(4):34-45. January 1983.

35. Telecon. Larson, J., MRI, with Gross, R., FCM Plastics Division,
Plastics Technologies, Inc. March 26 and April 3, 1984. Discussion
of electroless plating and electrostatic spray coating of plastic
parts.

36. Telecon. Duletsky, B., MRI, with Oberle, D., Udylite, Division of
Occidental Chemicals. March 30, 1984. Discussion of electroless
plating and electrostatic coating of plastic parts.

37. Telecon. Duletsky, B., MRI, with Beck, G., Nordson Corp. April'18,
1984. Discussion of electrostatic coating of plastic parts.

38. Letter and attachments from Walberg, A. C., Arvid C. Walberg and
Company, to Newton, D., MRI. March 29, 1983. Information on the
electrostatic spray coating of plastic parts.

39. Wilson, A. Methods for Attaining VOC Compliance. Pollution
Engineering. 15:34-35. April 1983.
3-23
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40. Letter from Robinson, E., Society of the Plastics Industry, to
Salman, D., EPA. August 31, 1984. Comments on draft BID Chapters 3
through 6.

41. Telecon. Glanville, J., MRI, with Webb, J., and Simmons, I., Eastman-
Kodak Company. July 14, 1983. Coatings, processes, and trends in
the surface coating of plastic parts for business machines.

42. Telecon. Glanville, J., MRI, with Pick, R., Craddock Finishing.
July 20, 1983. Coatings, processes, and trends in the surface coating
of plastic parts for business machines.

43. Armstrong, H. Presentation to the National Air Pollution Control
Techniques Advisory Committee (NAPCTAC). Graham Magnetics, Inc.
North Richland Hills, Texas. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 40 p.

44. Carpenter, R. Presentation to the NAPCTAC. Windsor Plastics, Inc.
Evansville, Indiana. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 7 p.

45. Lawson, D. Presentation to the NAPCTAC. PPG Industries, Inc.
Pittsburgh, Pennsylvania. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 4 p.

46. Leppek, D. Presentation to the NAPCTAC. Bee Chemical Co. Lansing,
Illinois. (Presented at the meeting of the NAPCTAC. Durham. May 1-2,
1985.) 6 p.

47. Godbey, F. Presentation to the NAPCTAC. Red Spot Paint & Varnish
Co., Inc. Evansville, Indiana. (Presented at the meeting of the
NAPCTAC. Durham. May 1-2, 1985.) 18 p.

48. Reilly, J. Presentation to the NAPCTAC. Electro-Kinetic Systems,
Inc. Trainer, Pennsylvania. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 7 p.

49. Kwok, K. C. Understanding Air Assisted Airless Technology and Its
Use in the Finishing Market. Grace Inc. Minneapolis, Minnesota.
Form number 314-587. October 1983. pp. 2-3.

50. Sinclair, R., Air-Assisted Airless Spray Painting. Products Finishing.
48(5):60-67. February 1984.

51. Telecon. Duletsky, B., MRI, with Scheidegger, C., Metamora Products
Corp. March 20, 1984. Discussion of electrostatic coating of plastic
shutters.

52. Poll, G. H., Jr. New System at Guide Paints Bumper Fascias. Products
Finishing. 48(2):38-34. November 1983.
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53. Telecon. Duletsky, B., MRI, with Thorpe, M. , Tafa Inc. August 21,
1984. Clarification of comments on draft BID Chapters 3 through 6.

54. Thorpe, M. L. Arc Sprayed Zinc Coating Is the Most Effective EMI
Shield for Plastics. Plastics Engineering. 38(4):23-26. April 1982.

55. Moriarty, J. W., Jr. Coatings That Provide EMI Shielding for Plastics.
University of Lowell, Lowell, Massachusetts. (Presented at the 40th
Annual Technical Conference and Exhibition of the Society of Plastics
Engineers. San Francisco. May 10-13, 1982.) 3 p.

56. Letter and attachments from Thorpe, M., Tafa Inc., to Salman, D., '
EPArCPB. July 24, 1984. Comments on draft BID Chapters 3 through 6.

57. Storms, C. D. EMI/RFI Shielding. In: Finishing '83 Conference
Proceedings. Dearborn, Association for Finishing Processes of the
Society of Manufacturing Engineers. 1983. pp. 23-44.

58. Hughes, T. E. Organic Coatings for EMI Shielding. Products Finishing.
48(1):64-67. October 1983.

59. Letter and attachments from Benson, P., Graham Magnetics, to Wyatt, S.,
EPA:CPB. August 20, 1984. Response to EPA request for coating
samples.

60. Letter and attachments from Choudary, H., Emerson and Cuming, to
Wyatt, S., EPA:CPB. August 16, 1984. Response to EPA request for
coating samples.

61. Letter and attachments from Ciller, R. , General Electric Insulating
Materials, to Salman, D., EPA:CPB. Information on Emilux 1832,
waterborne conductive coating.

62. Recognized Component Directory. Underwriters Laboratories, Inc.
1984. pp. 1276-1311.

63. Memo from Newton, D., MRI, to Salman, D., EPA:CPB. September 15,
1983. Site Visit—MDS-Qantel Corp., Hayward, California.

64. Telecon. Larson, J., MRI, with Salem, B., Seleco, Inc. June 30, 1985.
Discussion about Seleco1s selectve plating process.

65. Simon, R. M. EMI Shielding Through Conductive Plastics. Transmet
Corp., Columbus, Ohio. (Presented at the 40th Annual Technical
Conference and Exhibition of the Society of Plastics Engineers. San
Francisco. May 10-13, 1982.) 4 p.

66. Telecon. Grossman, R., Transmet Corp., with Newton, D., MRI. April 3,
1984. Discussion of conductive plastics.

67. Telecon. Larson, J., MRI, with Thomas, G., ThenSherwin-Williams
Company. June 10, 1985. Information on Polane® H.
3-25
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68. Telecon. Larson, J., MRI, with Kyle, H., Hewlett-Packard. June 12
and 17, 1985. Information on coatings usage.

69. Memo from Hester, C. and Newton, D., MRI, to Salman, D., EPArCPB.
September 20, 1983. Site Visit—E.M.A.C., Inc., Oakland, California.

70. Telecon. Larson, J., MRI, with Holt, R., The Sherwin-Williams Company.
March 14, 1985. Information on coatings.

71. Telecon. Larson, J., MRI, with Godbey, F., Red Spot Paint and Varnish
Company. June 6, 1985. Information on waterborne and higher solids
organic-solvent-based exterior coatings.

72. Telecon. Salman, D., EPA:CPB, with Watson, B., The Sherwin-Williams
Company. February 27 and April 30, 1985. Information on higher
solids exterior urethane coatings.

73. Telecon. Larson, J., MRI, with Leppek, D. , Bee Chemical Company.
June 7, 1985. Discussion about higher solids acrylic coating and
about VOC emissions from EMI/RFI shielding operations.

74. Letter and attachments from Dayton, J., PPG Industries, to Maurer, E. ,
MRI. January 6, 1984. Information about higher solids acrylic
coating.

75. Letter and attachments from Forbes, R., Eastman Kodak Company, to
Salman, D., EPArCPB. August 24, 1984. Comments on draft BID Chapters 3
through 6.

76. Maynard, G. T. Xerox Switches to Waterborne Texture. Industrial
Finishing. 59:23. May 1983.

77. Memo from Hester, C., MRI, to Salman, D., EPArCPB. March 14, 1983.
Site Visit—IBM Corp., Research Triangle Park, North Carolina.

78. Telecon. Maurer, E., MRI, with Leinbach, P., Reliance Universal.
January 4, 1984. Waterborne coatings for business machine parts.

79. Von Hor, R. C. The Processor's View of Relative Costs of the New
Technology Paints for Structural Foam Products. Ex-Cell-0 Corp.,
Athens, Tennessee. (Presented at the SPI Structural Foam Conference.
Atlanta. April 18-20, 1983). 23 p.

80. Letter from Price, M., Reliance Universal, Inc., to Salman, D.,
EPA:CPB. August 30, 1984. Comments on draft BID Chapters 3 through
6.

81. Telecon. Newton, D., MRI, with Cole, G., GCA Associates. June 16,
1983. Use of powder coatings to coat plastic parts.
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82. Telecon. Newton, D. , MRI, with Phillips, J., Bay Area Air Quality
Management District. June 15, 1983. Regulations for control of
emissions from the surface coating of plastic parts. }

83. Letter and attachments from Newberry, K., Missouri Department of
Natural Resources, to Newton, D., MRI. November 16, 1983. Information
on regulation to control VOC emissions from the surface coating of
plastic parts. !

84. Telecon. Newton, D., MRI, with Basilio, L., South Coast Air Quality
Management District. February 10, 1983. Coatings, processes, and
trends in the surface coating of plastics and regulations affecting
VOC emissions from the surface coating of plastic parts.
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4. EMISSION CONTROL TECHNIQUES

This chapter describes techniques that are available to control
volatile organic compound (VOC) emissions from the surface coating of
plastic parts for business machines. The control techniques discussed
are the use of lower-VOC-content coatings, process modifications, and
add-on controls.
VOC emissions occur when organic solvents evaporate from coatings
that are used to finish the parts. Commonly used organic solvents
include ketones, esters, ethers, and saturated and unsaturated hydrocarbons.
VOC emissions also may occur as by-products of reactions that take place
as the coatings cure.
Assuming that 100 percent of the organic solvent sprayed evaporates
into the atmosphere, a materials balance approach can be used to estimate
VOC emissions from the coating process. Although no direct VOC emission
data are available for the individual steps in the spray-coating process,
estimates can be made of VOC emissions from various stages in the surface
coating process. Based on an average transfer efficiency of 25 percent
for the spray coating step, at least 75 percent of the VOC is emitted in
the spray booth due to overspray alone. Assuming that an additional
5 percent of the VOC evaporates in the booth from coating that adheres
to parts, a total of about 80 percent of the VOC is emitted in the spray
booth. The remaining 20 percent of VOC emissions occur in flash-off
areas and curing ovens. These estimates are comparable to estimates
that have been made for analogous coating lines in other industries.1-2
In Southern California, for example, the South Coast Air Quality Management
District (SCAQMD) found that almost 90 percent of the VOC emissions from
surface coating operations occur in the spray booth and/or the flash-off
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area.1 Similarly, for the spray-coating of large appliances, an estimated
80 percent of the VOC emissions occur in the spray booth and flash-off
area.2
The average transfer efficiency for the spray coating of plastic
parts is lower than it is for the spray coating of metal parts, which is
often done electrostatically; thus, more VOC is emitted in the spray
booth for plastic parts due to the increased overspray. Furthermore,
coatings applied to plastic parts must be able to dry at lower tempera-
tures, so they often contain lower boiling solvents than coatings for
metal parts. The rapid evaporation of these lower boiling solvents in
the spray booth and flash-off area means that only a small portion of
the VOC is emitted in the curing oven. For these reasons, the proportion
of VOC emissions occurring in the spray booth is greater at facilities
that coat plastic than at facilities that coat metal.
4.1 USE OF LOWER-VOC-CONTENT COATINGS
Emissions can be reduced by using coatings that contain less VOC
than conventional coatings. Examples of coatings in which the VOC
content is lower than that in conventional organic-solvent-based coatings
are:
1. Organic-solvent-based coatings containing >40 percent, by
volume, solids as applied, and
2. Waterborne coatings.
Exterior decorative/protective coatings and electromagnetic
interference/radio frequency interference (EMI/RFI) shielding coatings
are available in lower-VOC-content forms. The advantages and disad-
vantages of these coatings are discussed in the following sections.
4.1.1 Lower-VOC-Content Organic-Solvent-Based Exterior Coatings
Organic-solvent-based two-component catalyzed urethane coatings
containing between 40 and 54 percent, by volume, solids at the gun are
currently being used to coat plastic parts for business machines.3-7
The performance and ease of application of these coatings has been
demonstrated on the major types of plastics used in business machines,
as well as on metal parts.3 These coatings possess the same good adhesion
and durability as do the popular, lower solids urethane coatings that
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contain less than 40 percent, by volume, solids as applied.3-5,8 For
some of these coatings, col oriand texture coats can often be applied
without using a primer.3,8 The major disadvantage of these urethanes is
their limited pot life, which^ranges from 1 to 4 hours once the coating
and catalyst are mixed.3-5,8 iMetering systems are available that can
alleviate this problem by drawing the coating and the catalyst from
separate reservoirs and mixing them at or prior to the spray gun.
Two-component catalyzed urethane coatings containing at least
60 percent, by volume, sol ids;at the gun have been successfully used to
coat polystyrene (PS), polycarbonate (PC), polyphenylene oxide (PPO),
steel, and aluminum business machine parts, but are not currently being
used in production.9-14 Polystyrene (PS), which is sensitive to solvent
attack, has been coated with the higher solids urethane without applying
a protective waterborne primer as is commonly done when solvent-based
urethanes containing less than 60 percent, by volume, solids are
used.11,12,15 Significant reductions in production costs were possible
when higher solids coatings were used, because parts that previously
required three coats (prime coat, base or color coat, and texture coat)
were successfully finished using only two coats (base or color coat and
texture coat).3,12,15 Furthermore, surface preparation steps, including
sanding and filling, were deleted.4,5,8 The decrease in processing steps
resulted in decreased laborjand materials costs and higher production
rates.12 Also, each part was coated with fewer passes of the spray
gun, resulting in faster production. Use of these coatings substantially
reduced VOC emissions because they contained about 0.35 kg VOC/J2. of
coating (3.0 Ib VOC/gal of coating) as sprayed, compared to 0.60 kg
VOC/£ of coating (5.0 Ib VOC/gal of coating) for the conventional urethane
coatings. These coatings were recently reformulated to a lower volume
solids content of about 53 percent at the gun to extend their pot life
without using plural component metering equipment.13
Another two-component catalyzed urethane coating containing
approximately 60 percent, by volume, solids at the gun is currently
in the experimental stage, and is being tested by several OEM's.16
The long pot life of this coating (8 to 16 hours) allows this coating
to be sprayed without using plural component metering equipment.
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The major disadvantage of using higher solids urethane coatings is
that they may require the use of plural-component metering systems and
pumps that can generate 0.014 to 4.2 mPa (2 to 600 psi) fluid
pressure
3-5 9_12 15 17
Without a plural-component metering system, the
pot life of some of; these coatings is less than an hour. Due to the
technical nature of. the equipment, some coaters have experienced difficulty
in getting these systems to operate properly or have experienced
maintenance problems with them.17,18 Another disadvantage with these
coatings is that spray operators must be specially trained to use the
plural-component metering system in applying higher solids coatings at
the desired film thickness.19 Also, as the solids content is increased,
larger quantities of isocyanates are required, which may increase worker
exposures to isocyanates.19
A single-component organic-solvent-based acrylic thermoset coating
containing between 50 and 55 percent, by volume, solids at the gun
(about 0.42 kg VOC/& of coating [3.5 Ib VOC/gal of coating]) is being
used experimentally on both plastic and metal business machine
parts.4,20-22 This coating can be sprayed with conventional spray
equipment and can be cured by baking for 15 minutes at 60°C (140°F),
followed by 30 to 40 minutes drying at room temperature.21 It has been
successfully used to coat PRO, PC, other structural foams, and metals on
experimental coating lines, but production scale tests have not yet been
performed.4,20-22 The coating does not contain the isocyanate catalysts
that are used in two-component urethane coatings, so use of this coating
is one way to avoid exposing workers to isocyanates.4,22 This coating
can be used without a plural-component metering system because its pot
life is longer than that of the higher solids urethane coatings.
A single-component organic-solvent-based urethane coating containing
between 50 and 55 percent, by volume, solids at the gun (about 0.42 kg
VOC/£ of coating [3.5 Ib VOC/gal of coating]) has been tested on steel
and plastic.23 This coating can be sprayed with conventional spray
equipment and must be baked between 20 and 40 minutes at 60°C (140°F).
It does not require the plural-component metering equipment that is
needed to apply some two-component urethane coatings.23
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A two-component organic-solvent-based acryTic thermoset coating
containing approximately 60 percent, by volume, solids at the gun (about
0.34 kg VOC/2 of coating [2.8 Ib VOC/gal of coating]) is being tested by
several OEM's.24,25 This coating can be sprayed with conventional spray
equipment and must be baked for a minimum of 30 minutes at 60°C (140°F).
It has been successfully applied experimentally to many types of plastic,
but has limited use on metals.24 A major problem with the marketing of
this coating is the required bake period; many coaters have limited, if
any, bake facilities.24
It is not possible to apply uniform thin films (<0.5 mil) of the
higher solids coatings discussed above because of the difficulty,
relative to lower solids coatings, of spraying the small volume of coating
required per unit area. Therefore, higher solids coatings are not being
used for fog coating of parts with molded-in color and texture.
4.1.2 Lower-VOC-Content Organic-Solvent-Based EMI/RFI Shielding Coatings
An organic-solvent-based nickel-filled acrylic coating containing
25 percent, by volume, solids at the gun is available for application to
business machine housings to provide EMI/RFI shielding.27 The manufacturer
recommends it for use on modified PRO, foamed styrene, and PC. Because
of the high density of the nickel pigment, the coating is agitated
during application to prevent settling.27
An organic-solvent-based nickel-filled two-component catalyzed
urethane coating containing 25 percent, by volume, solids at the gun is
available for application to business machine housings to provide EMI/RFI
shielding.28 Nickel-filled urethane coatings provide a more durable
finish than nickel-filled acrylic coatings and, therefore, are less
susceptible to chemical or physical damage that could result in reduced
EMI/RFI shielding effectiveness.4,28,29
4.1.3 Waterborne Exterior Coatings
Waterborne exterior decorative/protective coatings that can be
cured at low temperatures are presently used on some plastic business
machine parts, although they are not as commonly used as organic-solvent-
based coatings. Waterborne coatings are being used to coat structural
foam parts that require substantial coating films and to coat straight-
injection-molded parts with molded-in color and texture that require
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films of 0.5 mil or less. Several large business machine manufacturers
have approved waterborne coatings for use on their products.30-33
The advantages attributed to waterborne coatings include reduced
fire hazards, ability to coat nonconductive substrates electrostatically,
easy cleanup, and the low cost and availability of the diluting solvent,
water.30/34,35 Waterborne coatings can be applied using air atomized,
air-assisted/airless, and electrostatic spray equipment.17,30,34,35
There are disadvantages associated with the use of waterborne
coatings. Because water is corrosive, rustproof spray equipment, usually
stainless steel, is recommended for use with waterborne coatings.36
Higher atomization pressures are required to spray waterborne coatings
than to spray solvent-based coatings, and this may result in lower
transfer efficiencies.5,18 Some coaters and coating manufacturers have
indicated that compared to organic-solvent-based coatings, waterborne
coatings are more expensive to use.3,8 In addition, waterborne coatings
dry more slowly than organic-solvent-based coatings due to slower evapora-
tion rates.37 This could lead to process problems if an applicator were
air-drying coated parts instead of using ovens.
The performance of waterborne coatings compared to organic-solvent-
based coatings is debated by coaters and coating manufacturers. Many
coaters feel that the adhesion, durability, and gloss of waterborne
coatings are inferior to that achieved with solvent-based
coatings.4,8,9,15,38 For some coaters the quality of the finish obtained
with waterborne coatings is acceptable, but for others it is not.9,15,30-34
The two major types of waterborne coatings presently used on plastic
parts for business machines are acid-catalyzed waterborne coatings and
waterborne acrylic emulsions. The resin used in the acid-catalyzed
coating is considered confidential by the manufacturer.39 The acrylic
coatings have been available longer and are more frequently used than
the acid-catalyzed coatings.4 The acrylic coatings usually contain no
greater than 37 percent, by volume, solids as sprayed and about
0.24 kg VOC/A of coating (~2.0 Ib VOC/gal of coating), less water. The
newly marketed, acid-catalyzed waterborne coating contains a higher
solids content than do the waterborne acrylics.4 Its VOC content is
estimated at about 0.18 kg VOC/A of coating (1.5 Ib VOC/gal of coating)
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at the gun.33 This coating is reported to have good adhesion and
resistance properties on plastic that compare favorably to the adhesion
and resistance properties of solvent-based urethanes.4,33
4.1.4 Waterborne EMI/RFI Shielding Coatings
Waterborne nickel-filled acrylic EMI/RFI shielding coatings are
available for application to business machine housings.40-45 One coating
is available that contains 0.23 kg VOC/J2. of coating (1.9 Ib VOC/gal of
coating), less water and about 34 percent, by volume, solids as applied.46
This coating has been approved by Underwriters Laboratories for its
adhesion to plastic.47 Another coating is available that contains
0.32 kg VOC/£ of coating (2.71 Ib VOC/gal of coating), less water and
about 32 percent, by volume, solids as applied.41 This coating has
shown excellent adhesion to most plastics, but is particularly effective
on thermoplastics such as PS, ABS, PC and PPO.48 Other coatings are
available that contain approximately 30 to 32.5 percent, by volume,
solids as applied.42,43 One of these coatings is being used in production
for application on injection-grade Lexan, and the other coating can be
applied to ABS, PC, and certain grades of Lexan.42,44,45 As noted earlier,
waterborne coatings require longer drying periods than organic-solvent-based
coatings. None of these coatings are widely used.
4.2 PROCESS MODIFICATIONS
Process modifications that might be used to reduce VOC emissions
from the surface coating of plastic parts for business machines are
discussed in this section. The two major types of process modifications
to reduce VOC emissions are improvements in transfer efficiency and the
use of surface finishing techniques that do not emit VOC.
4.2.1 Transfer Efficiency
Transfer efficiency is defined to be the ratio of the amount of
coating solids deposited on the surface of the coated part to the total
amount of coating solids sprayed. Improved transfer efficiencies result
in less overspray. Consequently, total coating consumption is reduced,
resulting in decreased VOC emissions. Transfer efficiencies can be
improved by using an application technique other than spray application,
such as dip coating, or by using a more efficient spray technique such
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as air-assisted airless spraying or electrostatic spraying instead of
conventional air atomized spraying. Transfer efficiencies can also be
improved by proper operation and maintenance of spray equipment, and by
manipulation of various operating parameters such as spray booth air
flow (within allowable limits dictated by regulatory and safety con-
siderations). Application techniques other than spray coating are
rarely used for coating plastic business machine parts, so they will not
be discussed. Air-assisted airless spraying and electrostatic air
spraying, which are demonstrated process modifications for improving
transfer efficiency, are discussed below.
4.2.1.1 Air-Assisted Airless Spray. Air-assisted airless spray
was originally developed for use in the furniture finishing industry,
but it is also in use at facilities that surface coat plastic parts for
business machines.17,49,50 In this technique, coating is atomized
without air by being forced through a specially designed nozzle. Further
atomization is achieved by the introduction of a low-pressure air stream.
The resulting spray is slower and less turbulent than that provided by
air spray, thus transfer efficiency is improved. With regard to exterior
coatings, air-assisted airless spray can achieve a transfer efficiency of
40 percent, as compared to 25 percent for conventional air spray.51
The main advantages of this technique are materials savings and
reduced VOC emission rates. Disadvantages include a higher capital
investment for equipment and the need to train spray operators to use
the equipment properly. Although air-assisted airless spray equipment has
been used in production at many facilities, it has not been used for
application of the higher solids two-component catalyzed urethane coatings
or for application of the texture coat.51 Also, one company has reported
difficulty in using it with conventional coatings.37
4.2.1.2 Electrostatic Air Spray. The limited use of electrostatic
spray coating for plastic parts used in business machines reflects the
difficulty of coating a nonconductive surface electrostatically. To use
electrostatic spray, the surface of the plastic part must be made con-
ductive so that a voltage difference can be maintained between the
atomized coating and the part being coated. This is usually achieved by
charging the atomized paint and grounding the part so that the coating
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is attracted to the part by electrostatic force. Atomization of the
coating can be achieved by air, airless, air-assisted airless or rotary
techniques. Only air atomized electrostatic spray methods have been
demonstrated for application of coatings to plastic parts for business
machines.52,53
In general, the major benefits attributed to electrostatic spraying
are reduced coating consumption and reduced VOC emissions due to increased
transfer efficiency. Transfer efficiencies achieved by electrostatic
spray techniques are reported to be from 30 to 90 percent, depending on
the type and shape of the part, the type of atomization, and the type of
coating.53,54 Transfer efficiency is generally higher for an automated
system than for a manual one, although automatic systems are only practical
for long coating runs of similar parts.55,56 The transfer efficiency of
electrostatic air spray is assumed to be at least as high as that of
air-assisted airless spray, that is, at least 40 percent.57
Disadvantages of electrostatic air spraying include increased
capital costs for special equipment and the presence of electrical
hazards for spray operators. In addition, touch-up coating is often
necessary due to the Faraday Effect.58 This is an electrostatic repulsion
phenomenon that prevents charged coating particles from entering recessed
areas on parts being coated. Since plastic parts, and particularly
structural foam parts, are especially useful when complex shapes with
many recesses are needed, the Faraday Effect may be a significant problem.
Simple shapes, which are less susceptible to the Faraday Effect, are
frequently more practical to form from metal.58
Electrostatic air spray coating of plastic business machine parts
is being accomplished in two ways. One method involves the application
of a conductive sensitizer to the plastic part before electrostatic
application of subsequent coats of paint.59 The conductive sensitizer
is typically an organic-solvent-based or waterborne salt solution that
is applied by dip coating, spray coating, or manual wiping onto the
plastic part. When the solvent evaporates, the hydrophilic salt attracts
moisture from the atmosphere and forms a conductive layer on the surface
of the plastic part. Up to four coats can then be applied electro-
statically.60 Although application of an organic-solvent-based conductive
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sensitizer would emit VOC, use of electrostatic air spray in applying
subsequent top coats would still reduce overall VOC emissions.57
Another method that is currently being used to prepare plastic
parts for electrostatic air spray application of decorative/protective
coatings is electroless deposition of a thin film of metal onto the
surface of the plastic part.55,61-63 Electroless plating is used pri-
marily for the purpose of EMI/RFI shielding and is described in
Section 4.2.2.2.2. This EMI/RFI shielding technique deposits a film of
metal on all exposed surfaces of a plastic part (i.e., both' interior and
exterior surfaces). The surface of the plastic is rendered conductive
and can be top-coated electrostatically.55,61-63
Methods that have been used in other industries to spray coat
plastic parts electrostatically include the use of conductive (waterborne)
coatings, the placement of a grounded metal image behind the part being
painted, and the deposition of a thin film of metal from the vapor phase
onto the plastic part by vacuum metallizing or sputtering prior to
electrostatic air spray coating.32,64,65 Although all of these techniques
appear to be feasible approaches to electrostatic air spray coating,
they have not been used for production coating of plastic business
machine parts.
Other potential ways of coating plastic parts electrostatically
include the grounding of the EMI/RFI shielding coating on the interior
surface of plastic housings, the use of the EMI/RFI shielding coating as
a conductive primer that is applied to the exterior surface of plastic
housings and grounded during electrostatic top-coating, and the use of
conductive plastics. Some of these techniques are being studied experi-
mentally but have not been used in production.54
The grounding of the EMI/RFI shielding coating on the interior
surface of the plastic part would be analogous to using a grounded metal
image behind the plastic part being coated. The effectiveness of this
technique depends on the conductivity of the EMI/RFI shielding material
and the uniformity of the EMI/RFI shielding coating film.54
The feasibility of applying the EMI/RFI shielding coating to the
exterior surface of plastic housings to serve as a conductive primer has
not been evaluated.29,66 To serve this dual purpose, the conductive
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coatings would have to be chemically compatible with subsequent top
coats.28,29,67 For example, if the organic-solvent-based nickel-filled
acrylic lacquer coatings that are now commonly applied to housing interiors
were used as conductive exterior primers, they would be sensitive to
attack by some solvents present in subsequent top coats.29 This solvent
attack could lower the EMI/RFI shielding effectiveness of the coating.28,29
Organic-solvent-based nickel-filled urethane coatings would probably be
more successful as conductive exterior primers because they have greater
chemical resistance; however, the urethane coatings are more expensive
than the acrylic coatings.28,29
4.2.2 Surface Finishing Techniques That Do Not Emit VOC
Another type of process modification that can be implemented to
reduce VOC emissions is to use surface finishing techniques that do not
emit VOC. Finishing methods that do not emit VOC exist both for exterior
decorative applications and for EMI/RFI shielding applications.
4.2.2.1 Exterior Decorative Finishing. The major non-VOC-emitting
technique employed to provide an attractive finish on plastic parts used
in business machines is the use of molded-in color and texture. This
method relies on the use of straight injection molding techniques in
which pigment is added to the resin before or during the injection
molding step to provide the desired color. Molded-in texture requires
that the mold itself be tooled in such a way as to provide the desired
raised texture pattern on the molded parts. Parts with molded-in color
and texture cannot be produced using structural foam injection molding.
The use of molded-in color and texture is the method of choice for
some producers of plastic parts for business machines.68-71 Some manu-
facturers have reported significant savings by substituting the use of
molded-in color and texture for surface coating processes.70 Others
feel that the technology of molded-in color and texture does not provide
satisfactory color reproducibility and color stability, and does not
protect the plastic parts from environmental stress.9,15,72 Some coaters
report that plastic parts with molded-in color and texture still require
some surface coating.4,15 If too much coating is applied, however, the
molded-in texture may be masked.
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Cost considerations also influence the use of molded-in color and
texture. The mold used for straight injection molding is more expensive
than the mold used for structural foam injection molding. The reduction
in finishing costs realized by using molded-in color and texture (a
straight injection molding process) must, therefore, offset the higher
cost of the mold. The cost considerations affecting this choice are
complex and depend upon many factors including the size of the part, the
complexity of the shape of the part, and the number of parts produced
from the mold.
4.2.2.2 EMI/RFI Shielding. EMI/RFI shielding techniques that do
not emit VOC include zinc-arc spraying, electro!ess plating, the use of
conductive plastics, the use of metal inserts, and in some cases, vacuum-
metallizing and sputtering. Considerations other than VOC emissions
greatly influence the EMI/RFI shielding techniques used. Two important
considerations are shielding effectiveness and cost of a given technique.
Cost factors are discussed in Chapters 8 and 9. Simple comparisons of
EMI/RFI shielding effectiveness cannot be made among the different
shielding techniques. Shielding effectiveness depends upon the type of
material used for shielding, coating thickness, coating uniformity, and
the frequency of the EMI/RFI signals.
4.2.2.2.1 Zinc-arc spraying. Zinc-arc spraying is a two-step
process in which the plastic surface is roughened by sanding or grit-
blasting, and a coating of molten zinc is sprayed onto the roughened
surface. Advantages to zinc-arc spraying include high shielding
effectiveness over a wide range of frequencies and the fact that it is a
widely demonstrated EMI/RFI shielding technique. Disadvantages include
the need for special equipment such as a zinc-arc spray gun, a spray gun
air supply, a face shield and breathing air supply or respirator for the
operator, hearing protection, and a waterwash spray booth or baghouse
dust collector.73,74
4.2.2.2.2 Electro!ess plating. Electroless plating is a dip
process in which a film of metal is deposited from aqueous solution onto
all exposed surfaces of the part. The plastic parts are prepared for
electro!ess plating by oxidizing their surfaces with aqueous chromic and
sulfuric acids or with gaseous sulfur trioxide (S03). Following the
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oxidizing step, a metal film (usually copper, nickel, or chrome) is
electrolessly plated onto the plastic part,63,75 Advantages of electro-
less plating include the ability to coat the plated parts electrostatically,
low materials and labor costs, and good shielding effectiveness.55,61-64
One disadvantage is the incompatibility of electroless plating with
molded-in color unless masking is used. Another disadvantage is the
potential for VOC emissions if coatings that emit VOC's are applied
prior to the plating step so that only selected areas of the parts
are plated.76
4.2.2.2.3 Conductive plastics. Conductive plastics, which are
mixtures of resins and conductive fillers, are not widely used for
EMI/RFI shielding at the present time.77 These materials are being
studied extensively for their usefulness in business machine applications,
and some conductive plastics are already being used to make business
machine enclosures.77,78 Available resin types include ABS, ABS/PC
blends, PPO, nylon 6/6, polyvinyl chloride, and polybutyl terephthalate.
Conductive fillers include aluminum, steel, metallized glass, and carbon.
Advantages of using conductive plastics include elimination of the
EMI/RFI shielding finishing step and improved resistance to warping.
Disadvantages include high materials cost, less effective EMI/RFI shielding
especially when structural foam molding is used, and the addition of a
cosmetic finishing step to improve the surface appearance.78-80
4.2.2.2.4 Metal inserts. The use of metal inserts to house electronic
components within a plastic housing is a demonstrated EMI/RFI shielding
technique. The metal insert can be in the form of a metal box within a
plastic housing, metal foil laminated between layers of compression
molded plastic, metal foil glued inside the housing, or metal screens or
fibers placed within a plastic housing. Shielding effectiveness is
comparable to that obtained with metal housings.
4.2.2.2.5 Vacuum-metallizing or sputtering. Vacuum-metallizing
and sputtering are two similar techniques in which a thin film of metal
is deposited onto the plastic substrate from the vapor phase. Although
no VOC emissions occur during the actual metallizing process, solvent-
based prime coats and top coats are often sprayed onto parts to promote
adhesion and prevent degradation of the metal film. The VOC emission
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reduction potential of these techniques depends on the extent to which
VOC-containing prime coats and top coats are used, and the VOC content
of the coatings used. A disadvantage of these techniques is the need to
purchase additional equipment.
4.3 EMISSIONS CONTROL WITH ADD-ON CONTROL EQUIPMENT
Add-on control equipment such as carbon adsorbers, incinerators,
and condensers are presently being used to control VOC emissions at many
surface coating facilities, including magnetic tape coaters, fabric
coaters, and automobile coaters.81-83 No add-on control devices are
currently used by facilities that surface coat plastic parts used in
business machines. Most of the solvent-laden air (SLA) in these
facilities comes from the application/flash-off area. The concentration
of VOC in this air is very low because it must be diluted to protect
workers from breathing harmful levels of organic solvents, isocyanates,
and overspray. The amount of VOC in the air exhausted from the curing
ovens is low because about 90 percent of the solvent evaporates before
the coated parts enter the oven. Ovens can be operated at greater than
25 percent of the lower explosive limit (LEL) to minimize the costs of
operation and emissions control; however, only 10 percent of the total
emissions can be reduced by ducting oven emissions to a control device.84
The SLA from the application/flash-off area can be captured and
ducted to a control device, but the high volume of air and the low
concentration of VOC make this a costly method of control. For example,
the cost of using a thermal incinerator with primary heat recovery to
control VOC emissions from the spray booths and flash-off areas for a
medium-sized model plant (as defined in Chapter 6) is estimated to be
$11,000 to $21,000 per Mg ($10,000 to $19,000 per ton) of VOC controlled.
The specific cost depends on the booth ventilation rate.85
Although add-on control devices are not in use at facilities that
coat plastic parts for business machines, the general principles behind
carbon adsorption, incineration, and condensation are discussed in this
section.
4-14
-------
4.3.1 Carbon Adsorption
Carbon adsorption uses a bed of activated carbon to remove organic
vapors from an incoming airstream. The mechanism of VOC removal is
complex, but the removal efficiency is enhanced by specific charac-
teristics of the carbon. Its high surface-to-volume ratio and its
affinity for organics make activated carbon an effective adsorbent of
VOC.86 The VOC adsorption efficiency across a carbon bed can be at
least 95 percent if it is properly maintained and if VOC concentration
levels are sufficiently high.87
After a carbon bed has adsorbed a certain amount of VOC, a
breakthrough is reached beyond which the VOC removal efficiency decreases
rapidly. The bed must be regenerated before the breakthrough is reached,
otherwise saturation will occur and removal efficiency will become zero.
Typically, a carbon bed is regenerated by passing steam through the
carbon, countercurrent to the regular air flow, to strip the solvent
from the carbon. The effluent is condensed and then separated from the
residual water by decantation. The collected solvent may be reused,
sold, or disposed of as hazardous waste.
Figure 4-1 shows a typical carbon adsorption system.86 The two-bed
configuration allows for continuous operation of the coating facility
because one adsorber can be regenerated while the other is on-line.
4.3.2 Incineration
The two main types of incineration are thermal incineration and
catalytic incineration.
4.3.2.1 Thermal Incineration. A schematic diagram of a thermal
incinerator is shown in Figure 4-2.88 In this particular design, the
SLA is pre-heated by primary heat exchange with waste heat from the
combustion chamber. A burner is supplied with additional fuel that
ignites the pre-heated air stream. This process converts the incoming
VOC to carbon dioxide and water vapor.
Three important design considerations of the combustion chamber are
time, temperature, and turbulence. The residence time, which must be
sufficient to permit complete combustion of the VOC, is about 0.2 to
0.8 seconds. The necessary temperature range for thermal incineration
'is 760° to 870°C (1400° to 1600°F). Turbulence facilitates the mechanical
4-15
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4-17
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mixing of oxygen, heat, and VOC necessary for maximum destruction
efficiency.88 A properly designed incinerator can achieve destruction
efficiencies of 98 percent if VOC concentration levels are sufficiently
high.89
4.3.2.2 Catalytic Incineration. Figure 4-3 shows a typical catalytic
incinerator. The SLA enters the device from the oven or application
area. It is preheated to 260° to 460°C (500° to 860°F) and blown across
a catalyst site where oxidation occurs.88 About 98 percent of the
incoming VOC can be removed in this manner.89
The catalyst accelerates the rate of oxidation without undergoing a
chemical change itself. Typical materials used are noble metals, such
as platinum or palladium, dispersed on an alumina support. Combustion
temperatures are lower for catalytic incinerators than for thermal
incinerators.
4.3.3 Condensation
Condensation is a method of capturing VOC emissions by cooling
solvent-laden gases to the dew point of the solvent and collecting the
liquid droplets. Liquid nitrogen and air are typical coolants used in
the shell and tube surface condenser shown in Figure 4-4. Heat is
extracted from the incoming air stream as it passes through the cooled
metal tubes. When the vapor condenses, it is collected and either
reused or discarded, depending on its purity.90 Removal efficiencies
are comparable to those of the previously discussed add-on devices if
the condenser is properly designed and VOC levels are sufficiently
high.86
4.4 EMISSION SOURCE TEST DATA
There are no data available on control equipment because n
-------
SOLVENT-FREE
AIR
CATALYST
SITE
BLOWER
SOLVENT-LADEN
AIR
PREHEATER
Figure-4-3. Catalytic incinerator
4-19
-------
COOLANT VAPOR
INLET OUTLET
COOLANT CONDENSED
OUTLET VOC
VAPOR
INLET
Figure 4-4. Shell and tube surface condenser.
4-20
-------
process. For example, if an average transfer efficiency of 25 percent

is assumed, then at least 75 percent of the total VOC emissions occur in

the spray booth during the spray application step. On the average, it

is estimated that about 80 percent of the VOC emissions occur in the

spray booths, about 10 percent occur in the flash-off areas, and the
remaining 10 percent occur in the curing ovens.

4.5 REFERENCES FOR CHAPTER 4

1. Wilson, A. Methods for Attaining VOC Compliance. Pollution
Engineering. 15:34-35. April 1983.

2. Industrial Surface Coating: Appliances-Background Information for
Proposed Standards. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. EPA-450/3-80-037a.

3. Vacchiano, T. Painting Plastics for Business Machines. Products
Finishing. 45(5):62-66. February 1981.

4. Telecon. Newton, D., MRI, with Von Hor, R., Ex-Cell-0 Corporation.
July 22, 1983. Coatings, processes, and trends in the surface
coating of plastic parts for business machines.

5. Telecon. Newton, D., MRI, with Holt, R., Sherwin-Williams Company.
July 15, 1983. Coatings, processes, and trends in the surface
coating of plastic parts for business machines.

6. Larson, J., MRI, with Rose, D., The Sherwin-Williams Company.
June 6, 1985. Information^given on coating parameters and costs
for Polane^ T Plus, Polane^ W2, and Polane® HST.

7. Larson, J., MRI, with Rhodes, C., The Sherwin-Williams Company.
June 11, 1985. Information given on coating usage.

8. Von Hor, R.C. The Processor's View of Relative Costs of the New
Technology Paints for Structural Foam Products. Ex-Cell-0 Corporation,
Athens, Tennessee. (Presented at the SPI Structural Foam Conference.
Atlanta. April 18-20, 1983). 23 p.

9. Telecon. Newton, D., MRI, with Bond, S., MDS-Qantel Corporation.
July^28, 1983. Coatings, processes, and trends in the surface
coating of plastic parts for business machines.

10. Memo from Newton, D., MRI, to Salman, D., EPA:CPB. September 15,
1983. Site visit—MDS-Qantel Corporation, Hayward, California.

11. Memo from Hester, C. , and Newton, D. , MRI, to Salman, D. , EPA-.CPB.
September 20, 1983. Site visit—EMAC, Inc., Oakland, California.
4-21
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12. The Sherwin-Williams Company. Chemical Coatings News. Issue
No. 9. Chicago, Illinois. Fall 1983. pp. 1-2.

13. Telecon. Salman, D., EPArCPB, with Watson, B., The Sherwin-Williams
Company. February 27 and April 30, 1985. Information on higher
solids exterior urethane coatings.

14. Telecon. Larson, J., MRI, with Thomas, G.^ The Sherwin-Williams
Co. June 10, 1985. Information on Polane H.

15. Telecon. Newton, D., MRI, with Harris, G., EMAC, Inc. July 20,
1983. Coatings, processes, and trends in the surface coating of
plastic parts for business machines.

16. Telecon. Larson, J., MRI, with Godbey, F., Red Spot Paint and
Varnish Company. June 6, 1975. Information on waterborne and
higher solids organic-solvent-based exterior coatings.

17. Letter from Miller, M., Graco Inc., to Salman, D., EPA:CPB. August 8,
1984. Comments on draft BID Chapters 3 through 6.

18. Memo from Glanville, J., MRI, to Salman, D., EPA:CPB. September 7,
1983. Site visit—Ex-Cell-0 Corporation, Athens, Tennessee.

19. Telecon. Maurer, E., MRI, with Jackson, M., Bee Chemical. January 3,
1984. Discussion of coatings and cost information for the surface
coating of plastic business machine parts.

20. Telecon. Newton, D., MRI, with Dayton, J., PPG Industries. October 12,
1983. Information about higher solids acrylic coating manufactured
by PPG Industries.

21. Letter from Dayton, J., PPG Industries, to Maurer, E., MRI. January 6,
1984. Information about higher solids acrylic coating manufactured
by PPG Industries.

22. Telecon. Newton, D., MRI, with Maynard, G., Xerox Corporation.
March 28, 1984. Discussion of low-VOC-content coatings, EMI/RFI
shielding methods, and electrostatic coating of business machine parts.

23. Letter from Steele, W., Pratt and Lambert, to Berry, J., EPA:CPB.
August 6, 1984. Response to draft of emission standards.

24. Telecon. Larson, J., MRI, with Leppek, D., Bee Chemical Company.
June 7, 1985. Discussion about higher solids acrylic coating and
about VOC emissions from EMI/RFI shielding operations.

25. Telecon. Larson, J., MRI, with Farrell, K., Bee Chemical Company.
May 30 and 31, 1985. Information given on various coatings.

26. Bee Chemical Company. B-85 low-VOC business machine coating.
Lansing, Illinois. Undated.
4-22
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27. Graham Magnetics Inc. Cobaloy® P-212 Type 1A Conductive Coating,
and Cobaloy P-212 Type 1AHS Conductive Coating. North Rich!and
Hills, Texas. September 1983.

28. Telecon. Larson, J., MRI, with Dickinson, L., Bostik Division.
April 10, 1984. Information about conductive coatings manufactured
by Bostik, and discussion of electrostatic spray coating of plastics.

29. Telecon. Duletsky, B., MRI, with Proulx, D., Electro Kinetic
Systems, Inc. March 12, 1984. Discussion of EMI/RFI shielding
coatings.
30. Maynard, G. L. Xerox Switches to Waterborne Texture.
Finishing. 59:26. May 1983.
35.
36.
37.
38.
39.
Industrial
31. Telecon. Glanville, J. , MRI, with Kajewski, S. , Storage Technology
Corporation. July 14, 1983. Coatings, processes, and trends in
the surface coating of plastic parts for business machines.

32. Memo from Hester, C. , MRI, to Salman, D. , EPA:CPB. March 14, 1983.
Site visit—IBM Corporation, Research Triangle Park, North Carolina.

33. Telecon. Maurer, E. , MRI, with Leinbach, P., Reliance Universal.
January 4, 1984. Information on acid- catalyzed waterborne coatings.

34. Letter and attachments from Walberg, A.C. , Arvid Walberg and Company,
, .. ,
to Newton, D. , MRI. March 29, 1983. Information on the electro-
static spray coating of plastics using waterborne coatings.

Letter and attachments from Shoer, L. , Waterlac® Industries, Inc.,
to Salman, D. , EPA. December 7, 1983. Information on waterborne
coatings for business machine applications.

Telecon. Maurer, E. , MRI, with Burls, G. , Nordson Corporation.
January 6, 1984. Information on coating equipment.

Letter from Howard, S. , Southeastern Kusan, Inc., to Berry, J. ,
EPA:CPB. May 10, 1985. Comments on the National Air Pollution
Control Advisory Committee (NAPCTAC) meeting held May 1-2, 1985,
Durham, North Carolina.

Telecon. Newton, D. , MRI, with Howard, S. , Southeastern-Kusan,
Inc. March 7, 1983. Coatings, processes, and trends in the surface
coating of plastic parts for business machines.

Telecon. Newton, D. , MRI, with Carrol, L. , Reliance Universal.
August 24, 1983. Information about acid-catalyzed waterborne
coating.
40. Telecon. Newton, D., MRI, with Kelley, J., G. E. Insulating Materials.
May 31, 1984. Information about Emilux 1832, waterborne EMI/RFI
shielding coating.
4-23
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41. Letter from Choudhary, H., Emerson and Cunring, to Wyatt,@S., EPA:CPB.
August 16, 1984. June 5, 1984. Information on Eccocoat CC-33W,
waterborne EMI/RFI shielding coating.

42. Armstrong, H. Presentation to the NAPCTAC. Graham Magnetics, Inc.
North Rich!and Hills, Texas. (Presented at the meeting of the
NAPCTAC. Durham. May 1-2, 1985.) 40 p.

43. Godbey, F. Presentation to the NAPCTAC. Red Spot Paint and Varnish
Company, Inc. Evansville, Indiana. (Presented at the meeting of
the NAPCTAC. Durham. May 1-2, 1985.) 18 p.

44. Red Spot Paint and Varnish Company. Attenulac SON waterborne nickel
electromagnetic shielding laquer. Evansville, Indiana. January 11,
1984.

45. Telecon. Smith, S., MRI, with Armstrong, H., Graham Magnetics, Inc.
June 26, 1985. Information on higher solids Cobaloy P-212 type 4
series coatings.

46. Letter and attachments from Giller, R., General Electric Insulating
Materials, to Salman, D., EPArCPB. Information on Emilux 1832,
waterborne conductive coating.

47. Recognized Component Directory. Underwriters Laboratories, Inc.
1984. p. 1305.

48. Emerson and Cuming. Eccocoat® CC-33W Waterborne Conductive Coating.
Canton, Mass. October 1983.

49. Telecon. Duletsky, B., MRI, with Kwok, K., Graco, Inc. June 11,
1984. Information on air-assisted airless equipment developed by
Graco, Inc.

50. Telecon. Duletsky, B., MRI, with Pick, R., E/M Lubricants, Inc.
May 10, 1984. Discussion of current practices in the surface
coating of plastic parts for business machines.

51. Memo from Duletsky, B., MRI to the Project File. October 22, 1984.
Use of air-assisted airless spray technology for the surface coating
of plastic parts for business machines.

52. Memorandum from Salman, D., EPA:CPB, to Berry, J., EPA:CPB. August 14,
1984. Telephone conversation with K. C. Kwok, Graco, Inc., August 10,
1984.

53. Letter and attachments from Walberg, A., An/id C. Walberg & Co., to
Salman, D., EPA:CPB. August 17, 1984. Comments on draft BID
Chapters 3 through 6.
4-24
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54. Telecon. Duletsky, B., MRI, with Beck, G., Nordson Corporation.
April 18, 1984. Discussion of electrostatic coating of plastic
parts.

55. Telecon. Larson, J., MRI, with Gross, R., FCM Plastics Division,
Plastics Technologies, Incorporated. March 26 and April 3, 1984.
Discussion of electro!ess plating and electrostatic coating of
plastic business machine parts.

56. Telecon. Larson, J., MRI, with Harman, C., Cashier's Structural
Foam Division, Consolidated Metco, Incorporated. April 5, 1984.
Discussion of electrostatic coating of plastic business machine
parts.

57. Memo from Duletsky, B., MRI, to the Project File. July 11, 1984.
Use of electrostatic spray techniques for the surface coating of
plastic parts for business machines.

58. Telecon. Newton, D. , MRI, with Maynard, G., Xerox Corporation.
March 28, 1984. Discussion of electroless plating and electrostatic
coating of plastic business machine parts.

59. Poll, G. H., Jr. Programmed Painting at Texas Instruments. Products
Finishing. 47(4)-.34-35. January 1983.

60. Letter and attachments from Panzer, J., HSC Corporation, to Duletsky, B.,
MRI. March 14, 1984. Information on conductive sensitizers.

61. Telecon. Duletsky, B., MRI, with Oberle, D., Udylite Plating
Systems. March 30, 1984. Discussion of electroless plating and
electrostatic coating of plastic business machine parts.

62. Telecon. Larson, J., MRI, with Krulik, G., Enthone, Incorporated.
March 23, 1984. Discussion of electroless plating and electrostatic
coating of plastic business machine parts.

63. McCaskie, J. E., C. Tsiamis and H. Gerhardt. Vapor Etching Process
for EMI/RFI Shielding. Modern Plastics. 60:66-67. March 1983.

64. Poll, G. H., Jr. New System at Guide Paints Bumper Fascias.
Products Finishing. 48(2):38-44. November 1983.

65. Telecon. Newton, D., MRI, with Bell, J., Jay Plastics. March 1,
1983. Discussion of sputtering and electrostatic coating of plastic
parts.

66. Telecon. Newton, D., MRI, with Hughes, T., Advanced Chemicals and
Coatings. March 7, 1984. Discussion of EMI/RFI shielding coatings.

67. Hughes, T. E. Organic Coatings for EMI Shielding. Products Finishing.
48(1):64-67. October 1983.
4-25
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68. Telecon. Glanville, J., MRI, with Clockedile, A., Digital Equipment
Corporation. July 14, 1983. Coatings, processes, and trends in
the surface coating of plastic parts for business machines.

69. Letter and attachments from Brewer, W., NCR Corporation, to Farmer, J. ,
EPA. September 29, 1983. Response to Section 114 letter on the
surface coating of plastic parts for business machines.

70. Forger, G. Apple Moves to Injection, Cuts Costs Over $8 Million.
Plastics World. 41:32-34. May 1983.

71. Three Ways to Produce a Desktop Computer Housing. Plastics World.
40:34-39. September 1982.

72. Memo from Hester, C., MRI, to Salman, D., EPA:CPB. April 15, 1983.
Site visit—Southeastern-Kusan, Incorporated, Inman, South Carolina.

73. Moriarty, J. Coatings That Provide EMI Shielding for Plastics.
University of Lowell, Lowell, Mass. (Presented at the 40th Annual
Technical Conference and Exhibition of the Society of Plastics
Engineers, San Francisco, Calif. May 10-13, 1982.) 3 p.

74. Letter and attachments from Thorpe, M., Tafa Inc., to Salman, D.,
EPA:CPB. July 24, 1984. Comments on draft BID Chapters 3 through
6.

75. Krulik, G. EMI/RFI Shielding—A Boon for Electro!ess Plating.
Industrial Finishing. 59:16-18. May 1983.

76. Telecon. Larson, J., MRI, with Salem, B., Seleco, Inc. June 30,
1985. Discussion about Seleco1s selective plating process.

77. Ellis, J. R., and R. S. Schotland. Electrically Conductive Polymeric
Systems Market Outlook. Princeton Polymer Laboratories, Inc.,
Plainsboro, N.J'., and Schotland Business Research, Inc., Princeton,
N.J. (Presented at the 40th Annual Technical Conference and Exhibition
of the Society of Plastics Engineers. San Francisco. May 10-13,
1982.) 3 p.

78. Conductive Plastics. Chemical Week. 133(3):38-42. July 20, 1983.

79. Telecon. Newton, D., MRI, with Grossman, R., Transmet Corporation.
April 3, 1984. Discussion of conductive plastics.

80. Letter from Gross, R., FCM Plastics, to Salman, D., EPA:CPB.
August 21, 1984. Comments on draft BID Chapters 3 through 6.

81. Telecon. Meyer, J., MRI, with Harper, S., Verbatim. March 3,
1983. Use of emission control techniques at Verbatim.
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82. Telecon. Thorneloe, S., MRI, with Karger, E., Gates Rubber Company.
October 10, 1983. Control devices used in industries that surface-coat
fabric.

83. Automobile and Light-Duty Truck Surface Coating Operations—Background
Information for Proposed Standards. U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. EPA-450/3-79-030.
September 1979. pp. 4-27.

84. Gagliardi, C. Cutting Costs While Cleaning Air. EPA Journal.
10(4):40-41. May 1984.

85. Memo from Newton, D., MRI, to the Project File. February 17, 1984.
Cost effectiveness calculations for thermal incineration of VOC in
spray booth exhaust.

86. Danielson, John A. Air Pollution Engineering Manual. Research
Triangle Park, North Carolina. U.S. Environmental Protection
Agency. May 1973. pp. 189-202.

87. Crane, G. B. Carbon Adsorption for VOC Control. U. S. Environmental
Protection Agency. Chemicals and Petroleum Branch, Research Triangle
Park, North Carolina, p. 1.

88. Wark, K., and C. F. Warner. Air Pollution: Its Origin and Control.
New York, Harper and Row. 1976. pp. 301-311.

89. Memorandum from Mascone, D.C., Chemical Manufacturing Section to
Farmer, J. R., Chemicals and Petroleum Branch. June 11, 1980.
Thermal incinerator performance for NSPS.

90. U. S. Environmental Protection Agency. Organic Chemical Manu-
facturing, Volume 5: Adsorption, Condensation, and Absorption
Devices. Research Triangle Park, North Carolina. Publication
No. EPA-450/3-80-027. December 1980. p. II-2.
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5. MODIFICATION AND RECONSTRUCTION

New source performance standards promulgated in accordance with
Section 111 of the Clean Air Act, as amended, apply to all "affected
facilities" within the specified industry. Affected facilities include
those that commence construction after the proposal date of the standard,
as well as existing facilities that are modified or reconstructed after
the proposal date. The objective of this chapter is to clarify the
conditions under which an existing facility becomes an affected facility.
The following sections define "modification" and "reconstruction," as
put forth in the Code of Federal Regulations, and present examples of
these processes by which an existing facility becomes subject to the
performance standards.
5.1 GENERAL PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.1.1 Definition of Modification
Section 40 CFR 60.14(a) defines modification as follows:
Except as provided under paragraphs (e) and (f) of this
section, any physical or operational change to an existing
facility which results in an increase in the emission rate to
the atmosphere of any pollutant to which a standard applies
shall be considered a modification within the meaning of
Section 111 of the Act. Upon modification, an existing facility
shall become an affected facility for each pollutant to which a
standard applies and for which there is an increase in the
emission rate to the atmosphere.
Paragraph (b) specifies what constitutes an increase in emissions
and that methods to determine emission rate include the use of emission
factors, material balances, continuous monitor data, and manual emission
tests. Paragraph (c) affirms that the addition of an affected facility
to a stationary source does not by itself subject any other facility
within that source to the performance standards.
5-1
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Paragraph (e) lists the following physical and operational changes
which are not considered to be modifications:
1. Routine maintenance, repair and replacements.
2. Increase in production rate without capital expenditures.
3. Increase in hours of operation.
4. Use of, alternative fuel or raw material if, prior to proposal
of the standard, the facility was designed to accommodate that
alternative use.
5. The addition or use of an emission control device which would
result in decreased emissions from the facility.
6. Relocation or change in ownership of an existing facility.
Paragraph (f) allows for special provisions to be set forth, which
would supercede any conflicting provisions in this section. Paragraph (g)
sets a 180-day time period within which modified or reconstructed
facilities must achieve compliance with the promulgated standards.
5.1.2 Definition of Reconstruction
Section 40 CFR 60.15(b) defines reconstruction as follows:
An existing facility, upon reconstruction, becomes an
affected facility, irrespective of any changes in emission rate.
"Reconstruction" means the replacement of components of an
existing facility to such an extent that: (1) the fixed capital
cost of the new components exceeds 50 percent of the fixed
capital cost that would be required to construct a comparable
entirely new facility, and (2) it is technologically and
economically feasible to meet the applicable standards set forth
in this part.
The purpose of the reconstruction portion of the regulation is to
prevent an owner or operator from continuously replacing a few components
of an operating process except for support structures, frames, housing,
etc., in an attempt to avoid becoming subject to new source performance
standards.
5.2 APPLICABILITY'TO SURFACE COATING OF PLASTIC PARTS
In this section, the definitions of modification and reconstruction
are applied to specific examples of process changes which may occur at a
facility. The definitions and accompanying provisions are used to
determine whether or not each change would require the existing facility
5-2
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to comply with the standards. In practice, the final determination will
be made by the EPA on a case-by-case basis.
5.2.1 Examples of Potential Modifications
Examples of physical and operational changes which may increase
volatile organic compound (VOC) emission rates are listed in Table 5-1
and are discussed in this section. These changes would be classified as
modifications under the definition given in paragraph (a) of 40 CFR 60.14.
However, because of the superceding provisions in paragraph (e), only
two of the changes are classified as such. Table 5-1 indicates the
effect of each change on VOC emission rate, the governing provision for
that type of change, and whether or not the change is considered to be a
modification.
One type of change that could increase the VOC emission rate is
reformulation of the coating. This can be done either by switching from
a high solids to a lower solids coating or by adding VOC to the coating.
These changes would not be considered to be modifications, according to
40 CFR 60.14(e)(4). Under this provision, the use of an alternative raw
material does not constitute modification if the facility was originally
equipped to handle that raw material.
Another type of change that could increase the VOC emission rate is
the addition of application equipment. A facility may enlarge its spray
capacity by adding new spray guns in order to coat larger parts or to
increase production. These additions involve capital expenditures for
the facility, a situation which is not excluded by part (e)(2) of the
governing provision. Since increasing the production rate by adding
application equipment increases VOC emissions, this change constitutes
modification.
Increasing the conveyor line speed may increase the VOC emission
rate if the purpose is to meet rising production schedules. If the
speed is increased to meet cleaning or rinse time specifications, the
emission rate would not necessarily increase. In either case, no capital
expenditure is involved, so according to Part (e)(2) the change is not
modification.
Operational changes such as decreasing the conveyor speed, or
increasing the number of passes through the spray booths may be
5-3
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TABLE 5-1. EXAMPLES OF POTENTIAL MODIFICATIONS
Example
Effect on VOC Subpart of
emission rate 40 CFR 60.14(e)
Determination
of modification
1. Switching from a high Increase
to a lower solids
coati ng

2. Adding VOC to coating Increase

3. Adding application Increase
equipment

4. Increasing conveyor Possible
speed increase

5. Increasing hours of Same9
operation

6. Changing part size or Possible
complexity increase

7. Switching from coating Increase
of metal parts to
coating of plastic
parts

8. Substituting process Possible
equipment on a temporary increase
basis

9. Relocating a coating Same
operation from another
plant site
4

4
No

Yes

Yesc

No
Annual VOC emissions increase, although there is no effect on the hourly
.rate of emissions.
VOC emissions increase since there are no VOC emissions from the surface
coating of plastic parts when metal is being coated.
This is modification if construction of the metal coating facility
commenced after the proposal date of the standard. If construction
commenced prior to the proposal date, then this change would not be a
modification according to 40 CFR 60.14(e)4.
5-4
-------
implemented in order to increase coating thickness. Assuming that
production remains constant, these changes would result in increased
hours of operation. The total annual VOC emissions would, therefore,
increase while the hourly VOC emission rate would remain the same.
Since the number of hours of operation would increase, these changes
would be governed by subpart (e)(3) and would not be considered as
modifications.
Changing part size or complexity may increase the VOC emission
rate. A larger part size may increase paint consumption due to the
larger surface area of the part. Coating a more complex part may also
increase paint consumption, since transfer efficiency would be lower.
In both cases, VOC emissions would increase, but the change would not be
a modification if the facility was originally designed to accommodate
the new parts.
A facility that coats metal parts may begin coating plastic parts
without any changes or additional process equipment. If construction of
the metal parts coating facility commenced prior to proposal of the
standard, the change to begin coating plastic parts would not be a
modification, according to 40 CFR 14(e)(4). A facility built after proposal
of this NSPS that switched from coating metal parts to coating of plastic
parts would be covered under this NSPS as a new source.
Coating application equipment may be interchanged temporarily to
handle specific customer demands. Such a change may increase the VOC
emission rate but would not be a modification if it was made routinely
with existing equipment.
The last example given here of a potential modification is the
relocation of a coating operation from one plant site to another.
According to 40 CFR 60.14 (e)(6), this alone would not be considered a
modification. -
5.2.2 Examples of Reconstruction
According to 40 CFR 60.15(b), any equipment replacement that
involves a capital expenditure of more than 50 percent of the cost of a
comparable new facility is termed "reconstruction," regardless of the
change in VOC emission rate. Examples of changes to existing facilities
that may be considered as reconstruction are shown below:
5-5
-------
1. Coating application equipment is replaced or enlarged.
2. Conveyor equipment is replaced or enlarged.
Under the present regulations, changes such as these are not
required to be completed within a particular time. Once construction
has begun, an existing facility becomes an affected facility when the
expenditure exceeds 50 percent of the fixed capital cost of a comparable
new facility. The enforcement division of the appropriate EPA regional
office should be contacted whenever a source has questions regarding
modification and reconstruction.
5-6
-------
6. MODEL PLANTS AND REGULATORY ALTERNATIVES

This chapter describes model plants that are representative of
facilities that surface coat plastic parts used in business machines.
It also presents regulatory alternatives that define varying levels of
volatile organic compound (VOC) emission reductions below baseline from
these facilities.
6.1 MODEL PLANTS
Three model plants have been defined to include the major equipment
and techniques now being used to surface coat plastic parts for business
machines. The model plants are intended to reflect surface coating
facilities expected to be built in the future, whether they are in-house
coating operations of business machine manufacturers, large contractors
who perform both molding and coating of plastic parts, or job shops
performing coating services only. The three model plants represent
small (Plant A), medium (Plant B), and large (Plant C) facilities.
6.1.1 Production
The model plants presented in Table 6-1 were developed on the basis
of data gathered from industry and published literature. Annual coating
consumption data were selected as the basis for determining the size
categories because these data were more readily available than data
pertaining to the total surface area coated per year. The total amount
of solids sprayed is a function of coating formulation and annual
coating consumption. The amount of solids applied is based on an
estimated transfer efficiency of 25 percent of the total exterior
coating solids and 50 percent of the EMI/RFI shielding coating solids
sprayed under baseline conditions. These values are representative of
transfer efficiencies reported in published literature and estimated by
facilities that use air atomized spray equipment.1-12
6-1
-------
TABLE 6-1. MODEL PLANT PARAMETERS
a,b
Parameter
A.

B.
Plant A
Plant B
Plant C
Production
1.
2.
3.
Total volume of coating used at
capacity, 2/yr (gal/yr)
Total
Total
Operating
solids sprayed, i/yr
solids applied, £/yr
Parameters
(gal/yr)
(gal/yr)c

19,409 (5
6,420 (1
1,730

,127)
,696)
(457)

155,202 (41
51,368 (13
13,836 (3

,000)
,570)
,655)

388,030 (102
128,424 (33
34,591 (9

,507)
,926)
,138)

1. Period of Operation
a. h/d
b. d/wk
c. wk/yr

C. Process Parameters
1. Type and amount of coatings used
at baseline emission level
a. Solvent-based nickel-filled
acrylic for EHI/RFI shielding
containing 15%, by volume, solids
at the gun (17.3% of total coating
consumption)
i. Volume of coating sprayed,
£/yr (gal/yr)
ii. Volume of VOC sprayed,
JZ/yr (gal/yr)
iii. Volume of solids applied,
JZ/yr (gal/yr)
b. Solvent-based two-component
catalyzed urethane containing 32%,
by volume, solids at the gun (53.7%
of total coating consumption)
i.' Volume of coating sprayed,
i/yr (gal/yr)
ii. Volume of VOC sprayed,
£/yr (gal/yr)
iii. Volume of solids applied,
2/yr (gal/yr)
c. Solvent-based two-component
catalyzed urethane containing
50%, by volume, solids at the gun
(19.5% of total coating consump-
tion)
i. Volume of coating sprayed,
£/yr (gal/yr)
ii. Volume of VOC sprayed,
2/yr (gal/yr)
iii. Volume of solids applied,
2/yr (gal/yr)
d. Waterborne acrylic containing 37%,
by volume, solids at the gun, and
12.6%, by volume, organic solvent
at the gun (9.7% of total coating
consumption)
i. Volume of coating sprayed,
£/yr (gal/yr)
ii. Volume of VOC sprayed,
St/yr (gal/yr)
iii. Volume of solids applied,
3,/yr (gal/yr)c
16
5
50
16
5
50
3,331 (880) 26,498 (7,000)

2,831 (748) 22,523 (5,950)
250 (66)
1,987 (525)°
10,410 (2,750) 83,279 (22,000)

7,079 (1,870) 56,630 (14,960)

833 (220) 6,662 (1,760)
3,785 (1,000) 30,283 (8,000)

1,893 (500) 15,142 (4,000)

473 (125) 3,785 (1,000)
1,882 (497) 15,142 (4,000)

237 (63) 1,908 (504)

174 (46) 1,401 (370)
16
5
50
66,270 (17,507)

56,329 (14,881)

4,970 (l,313)c
208,198 (55,000)

141,574 (37,400)

16,656 (4,400)
75,708 (20,000)

37,854 (10,000)

9,464 (2,500)
37,854 (10,000)

4,770 (1,260)

3,502 (925)
(continued)
6-2
-------
TABLE 6-1. (continued)
Parameter
2. Zinc consumption for zinc-arc
EMI/RFI shielding
a. Total zinc sprayed, kg/yr (Ib/yr)
b. Zinc solids applied, kg/yr (Ib/yr)
3. Coating equipment
a. Conveyorized lines
b. Manual air atomized spray guns
c. Dry filter spray booths

Plant A

0
0

0
2
-2

Plant B Plant C

65,305 (144,101) 130,517 (288,000)
34,612 (76,374) 69,174 (152,640)
•
1 2
5 9
5 6
(2 batch; 3 on (2 batch; 4 on
conveyorized line) conveyorized

d. Waterwash spray booths6

e. Spray booth ventilation rate, m3/s
(acfm) f
f. Grit blasting booths
g. Zinc- arc spray booths9
h. Gas-fired intermediate bake ovens

i. Gas-fired final curing ovens

4. . Coating application
a. Average transfer efficiency
i. Prime and color coats
ii. Texture and touch-up coats
iii. EMI/RFI nickel-filled
shielding coat
b. Average dry film thickness for
EMI/RFI shielding coats
i. Metal-filled coatings
ii. Zinc-arc spray
c. Average dry film thickness for
exterior coats
i. Prime/filler coat
ii. Color coat
iii. Texture coat
iv. Total exterior film thickness
applied
d. Average flash-off period
i. EMI/RFI shielding
ii. Prime/filler coat
iii. Color coat
iv. Texture coat
e. Curing temperature and time in
intermediate bake oven
i. Prime/filler coat
ii. Color coat
f. Curing temperature and time 140°F
in final curing oven
g. Average conveyor speed, m/s
(ft/min)

4.7
(10,000)
0
0
0

25%
25%
50%

2 mil
3 mil

2 mil
1 milu
3 milh
6 mil

Variable
Variable
Variable
Variable

N/A1'
N/A
for 30 min

N/A

line No. 1)
0 3
(3 on conveyorized
line No. 2)
4.7 4.7
(10,000) (10,000)
2 4
2 4
0 1
(Conveyorized line
No. 2)
2 2
(1 batch oven; (1 batch oven;
1 multiple pass 1 multiple pass
oven on oven through which
conveyorized line) both conveyor
lines pass)

25% 25%
25% 25%
50% 50%

2 mil 2 mil
3 mil 3 mil

2 mil 2 mil
1 mil. 1 milu
3 mil" 3 mil"
6 mil 6 mil

12 min 12 min
12 min 12 min
12 min 12 min
12 min 12 min

N/A 120°F for 10 min
N/A 120°F for 10 min
140°F for 30 min 140°F for 30 min

0.04 (8) 0.04 (8)

(continued)
6-3
-------
TABLE 6-1. (continued)
Parameter
D. VOC Emissions
1. Total solvent (VOC) emissions,
Mg/yr (t/yr)
a. Percint VOC emissions from spray
booths
b. Percent VOC emissions from flash-off
areas
c. Percent VOC emissions from ovens
Plant A

10.6 (11.7)
80

10
Plant B

85 (94)
80

10
Plant C

212 (234)
80

10
aThe sets of values in the table were calculated by column in English units, then converted to metric
units. The conversion factors used were: (a) 1 gallon (gal) equals 3.7854118 liter (fi); and
. (b) 1 Hegagram (Hg) equals 1.1025 tons.
"Assume VOC density of 0.882 kg/£ (7.36 Ib/gal). .
Assuming 25 percent transfer efficiency for exterior coats and 50 percent transfer efficiency for
.EHI/RFI nickel-filled shielding coats.
°0oes not include coating solids applied by zinc arc spraying.
?0oes not include spray booths for grit blasting stations or zinc-arc spraying stations.
fIncludes dry filter spray booth and grit blaster.
Hlncludes waterwash spray booth and zinc-arc spray apparatus.
"Film thickness for texture coat cannot be measured because it is a spatter coating. The value is
based on the assumption that the volume of coating used for texture is spread uniformly over the
.surface areas coated.
WA « Hot applicable.
6-4
-------
6.1.2 Process Parameters
The most commonly used exterior coatings for plastic parts are
organic-solvent-based two-component catalyzed urethane coatings
containing about 30 percent, by volume, solids at the gun.1,13,14 The
majority of plants are also using some two-component catalyzed urethane
coatings containing approximately 50 percent, by volume, solids at the
1 13 14
Coatings containing greater than 60 percent, by volume,
gun.
solids at the gun, have been used in production in the past, but are
only being used experimentally at the present time.15-20 Therefore,
these higher solids coatings have not been included in the baseline.
Two-component catalyzed urethane coatings represent approximately
90 percent of the exterior coatings consumed for plastic parts used in
business machines, with the remaining 10 percent of exterior coatings
being waterborne acrylic emulsions.1,13,14
All three model plants have the capability to perform electromagnetic
interference/radio frequency interference (EMI/RFI) shielding, although
not all plastic parts require it. The EMI/RFI shielding usually is
accomplished by one of two methods: zinc-arc spraying, and the spray
application of organic-solvent-based metal-filled coatings. Each model
plant can perform shielding by the latter method, which uses conventional
spray equipment, but only the two larger plants have zinc-arc spray
capability, which involves the purchase of additional equipment.
Conveyorized lines also require a large capital investment that can
only be recovered by facilities with high production rates. For this
reason, the two larger model plants include conveyors in their coating
operations. The small model plant is designed only for batch coating,
in which one or more parts are manually placed in the spray booths for
coating and removed from the booths to dry. Figures 6-1 through 6-3
show schematic diagrams of the three model plants.
6.1.3 VQC Emissions
Because of the lack of State regulations controlling VOC emissions
from the surface coating of plastic parts, the baseline emission level
was determined using coating consumption data obtained from facilities
that surface coat plastic parts for business machines. Baseline emission
levels for the model plants are presented in Table 6-1. These represent
6-5
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the emission levels that would be expected if no new source performance
standard (NSPS) were developed. Table 6-2 shows baseline coating
utilization at a typical plant, including the VOC content of each coating
used.
6.2 REGULATORY ALTERNATIVES
Thirty-two regulatory alternatives have been developed by applying
the control technologies described in Chapter 4. Each alternative
represents a different level of VOC emission reduction for model plants
with constant levels of production. Because add-on emission control
devices are not cost-effective for facilities that surface coat plastic
parts for business machines, VOC emission reductions are achieved by
using spray technologies that reduce coating consumption or by using
coatings with lower VOC content. For example, an increased transfer
efficiency results in decreased coating consumption, and a higher solids
content results in a lower VOC content in the coating. Both approaches
are applied to the model plants as methods of reducing VOC emissions.
The regulatory alternatives are defined below, along with examples of
specific control strategies that could be used to achieve them. Regulatory
Alternatives 11-25 through XVI-25 reflect the emission reductions that
could be obtained if the model plants use lower-VOC-content coatings.
Regulatory Alternatives 1-25/40 through XVI-25/40 reflect the emission
reductions that could be obtained by both improving the transfer efficiency
for prime and color coats to 40 percent and using lower-VOC-content
coatings. The alternatives are summarized in Table 6-3.
6.2.1 Alternative 1-25 (Baseline)
The baseline emission level is the level of control that would
exist in the absence of an NSPS. This alternative reflects the current
industry practice, as shown for the model plants in Tables 6-1 and 6-2.
6.2.2 Alternative 11-25
Emissions are reduced approximately 11 percent below baseline
level. This reduction can be achieved by using EMI/RFI shielding coatings
containing 25 percent, by volume, solids. Waterborne and organic-solvent-
based exterior coatings usage remains the same as for the baseline case.
A VOC emission reduction of 47 percent is obtained for the EMI/RFI
6-9
-------
TABLE 6-2. BASELINE COATING UTILIZATION
Type of coating
Percent
solids,
by
volume,
at the
gun
Percent
of
total
coati ng
consump-
tion
VOC content
kg/£ of
coating
(Ib/gal of
coating),
less water
kg/£ of
solids
(Ib/gal
of
solids)
Solvent-based nickel- 15 17.1
filled EMI/RFI
shielding coating

Solvent-based coating 32 53.7
No. 1

Solvent-based coating 50 19.5
No. 2

Waterborne coating 37 9.7
(water/VOC = 80/20)
0.75 (6.3)
5.00 (42.0)
0.60 (5.0) 1.87 (15.6)
0.44 (3.7) 0.88 (7.3)
0.22 (1.9) 0.30 (2.5)
6-10
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shielding process, but emissions from the exterior coating process are
unchanged.
6.2.3 Alternative 111-25
Emissions are reduced approximately 21 percent below baseline
level. This reduction can be achieved by using waterborne EMI/RFI
shielding coatings. Waterborne and organic-solvent-based exterior
coatings usage remains the same as for the baseline case. A VOC
emission reduction of 89 percent is obtained for the EMI/RFI shielding
process, but emissions from the exterior coating process are unchanged.
6.2.4 Alternative IV-25
Emissions are reduced approximately 23 percent below baseline
level. This reduction can be achieved by using non-VOC-emitting EMI/RFI
shielding methods. Waterborne and organic-solvent-based exterior
coatings usage remains the same as for the baseline case. A VOC
emission reduction of 100 percent is obtained for the EMI/RFI shielding
process, but emissions from the exterior coating process are unchanged.
6.2.5 Alternative V-25
Emissions are reduced approximately 31 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 50 percent, by volume, solids. Waterborne
exterior coatings usage and EMI/RFI coatings usage remain the same as
for the baseline case. A VOC emission reduction of 41 percent is
obtained for the exterior coating process, but emissions from the
EMI/RFI shielding process are unchanged.
6.2.6 Alternative VI-25
Emissions are reduced approximately 42 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 50 percent, by volume, solids and by using
organic-solvent-based EMI/RFI shielding coatings containing 25 percent,
by volume, solids. Usage of waterborne exterior coatings remains the
same as for the baseline case. The VOC emission reductions obtained for
the EMI/RFI shielding process and the exterior coating process are
47 percent and 41 percent, respectively.
6-13
-------
6.2.7 Alternative VII-25
Emissions are reduced approximately 52 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 50 percent, by volume, solids and by using
waterborne EMI/RFI shielding coatings. Usage of waterborne exterior
coatings remains the same as for the baseline case. The VOC emission
reductions obtained for the EMI/RFI shielding process and the exterior
coating process are 89 percent and 41 percent, respectively.
6.2.8 Alternative VIII-25
Emissions are reduced approximately 46 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 60 percent, by volume, solids. Waterborne
exterior coatings usage and EMI/RFI coatings usage remain the same as
for the baseline case. A VOC emission reduction of 60 percent is
obtained for the exterior coating process, but emissions from the
EMI/RFI shielding process are unchanged.
6.2.9 Alternative IX-25
Emissions are reduced approximately 55 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 50 percent, by volume, solids and by using
non-VOC-emitting EMI/RFI shielding methods. Usage of waterborne
exterior coatings remains the same as for the baseline case. The VOC
emission reductions obtained for the EMI/RFI shielding process and the
exterior coating process are 100 percent and 41 percent, respectively.
6.2.10 Alternative X-25
Emissions are reduced approximately 57 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 60 percent, by volume, solids and by using
organic-solvent-based EMI/RFI shielding coatings containing 25 percent,
by volume, solids. Usage of waterborne exterior coatings remains the
same as for the baseline case. The VOC emission reductions obtained for
the EMI/RFI shielding process and the exterior coating process are
47 percent and 60 percent, respectively.
6-14
-------
6.2.11 Alternative XI-25
Emissions are reduced approximately 67 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 60 percent, by volume, solids and by using
waterborne EMI/RFI shielding coatings. Usage of waterborne exterior
coatings remains the same as for the baseline case. The VOC emission
reductions obtained for the EMI/RFI shielding process and the exterior
coating process are 89 percent and 60 percent, respectively.
6.2.12 Alternative XI1-25
Emissions are reduced approximately 60 percent below baseline
level. This reduction can be achieved by using waterborne exterior
coatings. Usage of EMI/RFI coatings remains the same as for the
baseline case. A VOC emission reduction of 78 percent is obtained for
the exterior coating process, but emissions from the EMI/RFI shielding
process are unchanged.
6.2.13 Alternative XIII-25
Emissions are reduced approximately 69 percent below baseline
level. This reduction can be achieved by using organic-solvent-based
exterior coatings containing 60 percent, by volume, solids and by using
non-VQC-emitting EMI/RFI shielding methods. Usage of waterborne
exterior coatings remains the same as for the baseline case. The VOC
emission reductions obtained for the EMI/RFI shielding process and the
exterior coating process are 100 percent and 60 percent, respectively.
.6.2.14 Alternative XIV-25
Emissions are reduced approximately 71 percent below baseline
level. This reduction can be achieved by using waterborne exterior
coatings and by using organic-solvent-based EMI/RFI shielding coatings
containing 25 percent, by volume, solids. The VOC emission reductions
obtained for the EMI/RFI shielding process and the exterior coating
process are 47 percent and 78 percent, respectively.
6.2.15 Alternative XV-25
Emissions are reduced approximately 81 percent below baseline
level. This reduction can be achieved by using waterborne exterior
coatings and by using waterborne EMI/RFI shielding coatings. The VOC
6-15
-------
emission reductions obtained for the EMI/RFI shielding process and the
exterior coating process are 89 percent and 78 percent, respectively.
6.2.16 Alternative XVI-25
Emissions are reduced approximately 83 percent below baseline
level. This reduction can be achieved by using waterborne exterior
coatings and by using non-VOC-emitting EMI/RFI shielding methods. The
VOC emission reductions obtained for the EMI/RFI shielding process and
the exterior coating process are 100 percent and 78 percent,
respectively.
6.2.17 Alternatives 1-25/40 through XVI-25/4Q
For Regulatory Alternatives 1-25/40 through XVI-25/40, emissions from
exterior coating processes are reduced approximately 14 percent below
the levels expected for Regulatory Alternatives 1-25 through XVI-25.
This reduction corresponds to an increase in transfer efficiency from
25 percent to 40 percent for prime and color coats, obtained by using
air-assisted airless or electrostatic air spray equipment. Table 6-4
illustrates the emission reduction potential of ^ach regulatory
alternative as a function of transfer efficiency.
6-16
-------
TABLE 6-4. EMISSION REDUCTION POTENTIAL OF REGULATORY ALTERNATIVES
AS A FUNCTION OF TRANSFER EFFICIENCY

VOC emission
reduction, wt % 25 25/40

0-10 I
11-15
II
16-20
21-25
III, IV
II
26-30
31-35
III
36-40
IV, V
41-45
VI
46-50
VIII
51-55
VII, IX
VI, VIII
56-60
X, XII
61-65
VII, IX, X, XII
66-70
XI, XIII
71-75
XIV
XI, XIII, XIV
76-80
81-85
XV, XVI
XV
86-90
XVI
91-95
96-100
25 percent transfer efficiency (TE) for exterior coating,
.50 percent TE for metal-filled EMI/RFI shielding coating.
40 percent TE for prime and color exterior coating, 25 percent
for texture and touch-up exterior coating, and 50 percent TE
for metal-filled EMI/RFI shielding coating.
6-17
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6.3 REFERENCES FOR CHAPTER 6

1. Telecon. Newton, D., MRI, with Von Hor, R., Ex-Cell-0 Corp. July 22,
1983. Coatings, processes, and trends in the surface coating of
plastic parts for business machines.

2. Letter and attachments from Hall, D., Premix, Inc., to Farmer, J.,
EPA. October 4, 1983. Response to Section 114 letter on the surface
coating of plastic parts for business machines.

3. Letter and attachments from Walberg, A. C., Arvid C. Walberg & Company,
to Newton, D., MRI. March 29, 1983. Information on the electrostatic
spray coating of plastic parts.

4. Wilson, A. Methods for Attaining VOC Compliance. Pollution Engineering.
15:34-35. April 1983.

5. Telecon. Glanville, J., MRI, with Webb, J., and Simmons, I., Eastman-
Kodak Co. July 14, 1983. Coatings, processes, and trends in the
surface coating of plastic parts for business machines.

6. Telecon. Glanville, J., MRI, with Fick, R., Craddock Finishing.
July 20, 1983. Coatings, processes, and trends in the surface coating
of plastic parts for business machines.

7. Armstrong, H. Presentation to the National Air Pollution Control
Techniques Advisory Committee (NAPCTAC). Graham Magnetics, Inc.
North Richland Hills, Texas. (Presented at the meeting of the NAPCTAC.
Durham, May 1-2, 1985.) 40 p.

8. Carpenter, R. Presentation to the NAPCTAC. Windsor Plastics, Inc.
Evansville, Indiana. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 7 p.

9. Lawson, D. Presentation to the NAPCTAC. PPG Industries, Inc.
Pittsburgh, Pennsylvania. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 4 p.

10. Leppek, D. Presentation to the NAPCTAC. Bee Chemical Co. Lansing,
Illinois. (Presented at the meeting of the NAPCTAC. Durham. May 1-2,
1985.) 6 p.

11. Godbey, F. Presentation to the NAPCTAC. Red Spot Paint & Varnish
Co., Inc. Evansville, Indiana. (Presented at the meeting of the
NAPCTAC. Durham. May 1-2, 1985.) 18 p.

12. Reilly, J. Presentation to the NAPCTAC. Electro-Kinetic Systems,
Inc. Trainer, Pennsylvania. (Presented at the meeting of the NAPCTAC.
Durham. May 1-2, 1985.) 7 p.
6-18
-------
13. Vacchiano, T. Painting Plastics for Business Machines. Products
Finishing. 45(5):62-66. February 1981.

14. Telecon. Newton, D., MRI, with Holt, R., Sherwin-Williams Company.
July 15, 1983. Coatings, processes, and trends in the surface coating
of plastic parts for business machines.

15. The Sherwin-Williams Company. Chemical Coatings News. Issue No. 9.
Chicago, Illinois. Fall 1983. pp. 1-2.

16. Memo from Newton, D., MRI, to Salman, D., EPA:CPB. September 15,
1983. Site Visit—MDS-Qantel Corp., Hayward, California.

17. Memo from Hester, C. and Newton, D., MRI, to Salman, D. , EPA:CPB.
September 20, 1983. Site Visit—E.M.A.C., Inc., Oakland, California.

18. Telecon. Larson, J., MRI, to Thomas^ G., Sherwin-Williams Company.
June 10, 1985. Discussion of Polane H, a higher solids two-component
catalyzed urethane coating.

19. Telecon. Larson, J., MRI, to Godbey, F., Red Spot Paint & Varnish
Co., Inc. June 6, 1985. Discussion of 284 series, a higher solids
two-component catalyzed urethane coating.

20. Telecon. Larson, J., MRI, to Leppek, D., Bee Chemical Co. June 7,
1985. Discussion of B-85, a higher solids two-component catalyzed
acrylic coating.
6-19
-------
-------
7. ENVIRONMENTAL IMPACT

This chapter presents a discussion of the environmental impact of
each of the regulatory alternatives that were presented in Chapter 6.
The discussion includes the impact of each regulatory alternative on
air, water and solid waste emissions, and on energy consumption. All
calculations and conclusions regarding environmental impact are based on
the model plants described in Chapter 6 and on the industry growth
projections presented in Chapter 8.
7.1 AIR POLLUTION IMPACT
The air pollution impact of each regulatory alternative is presented
in Section 7.1.1 in terms of volatile organic compound (VOC) emissions.
Consideration is given to other air emissions occurring during the
coating process in Section 7.1.2.
7.1.1 VOC Emissions
The contribution of specific coatings to the total VOC emissions
from each of the model plants discussed in Chapter 6 is shown in Tables 7-1,
7-2, and 7-3. Table 7-4 summarizes the total VOC emissions from model
plants A, B, and C for each regulatory alternative.
Nationwide VOC emissions from facilities that surface coat plastic
business machine parts and that will be subject to the new source perfor-
mance standard (NSPS) have also been estimated for each regulatory
alternative. Because statistical data on the coating process are sparse,
a number of assumptions were made to estimate both present and future
VOC emissions. The supporting data and underlying assumptions used to
estimate nationwide emissions are discussed in the following sections.
7-1
-------
7.1.1.1 Nationwide Emissions from Exterior Coating in 1985 and 1990.
The VOC emissions from exterior coating of plastic parts for business
machines were estimated by the following steps:
1. The mass of plastic consumed for business machines was calculated
using a 17 percent average annual growth rate from a baseline of 31.8 xlO6
kilograms (70 xlO6 Ib) of plastic consumed for business machines in
I960.1-3 A 50:50 split by weight was assumed between parts molded as
structural foam (SF) and straight-injection-molded (SIM) plastic. (See
Tables 7-5 and 7-6.)
2. The mass of SF and SIM plastic coated was calculated by assuming
that 90 percent of SF parts and 10 percent of SIM parts receive exterior
coatings.
3. The mass of SF and SIM plastic coated by plants covered by the
NSPS versus plants not covered by the NSPS was calculated by assuming
that one-third of the growth in surface coated plastic parts between
1985 and 1990 would be absorbed by plants not covered by the NSPS.
Plants not covered by the NSPS would include plastic parts coating
facilities built before proposal of the NSPS and metal parts coating
facilities built before proposal of the NSPS that switch to the coating
of plastic parts.
4. The surface areas of SF and SIM parts coated were calculated by
assuming an average density and thickness for each type of part. An
average SF part density of 1 g/cm3 (62.4 lb/ft3) and an average wall
thickness of 0.635 cm (0.25 in.) were assumed to calculate the surface
area of SF coated. An average SIM part density of 1.1 g/cm3 (68.6 lb/ft3)
and an average wall thickness of 0.318 cm (0.125 in.) were assumed to
calculate the surface area of SIM plastic coated. Estimates of surface
areas receiving exterior coating are presented in Tables 7-5 and 7-6.
5. The volume of coating solids applied to each type of part was
calculated by assuming an average exterior coating thickness of 6 mils
for SF parts and 0.5 mils for SIM parts and multiplying the film thickness
by the surface area coated.
6. The volume of exterior coating sprayed and the VOC emissions
occurring due to the spraying were calculated for each type of part by
applying the baseline coating utilization data to the volume of coating
7-2
-------
solids applied (calculated in Step 5) and by assuming'an average transfer
efficiency of 25 percent. Baseline exterior coating utilization for SF
parts is a mix of organic-solvent-based and waterborne coatings that was
described in Chapters 3 and 6. A "worst case" VOC emission number was
generated for coating SIM parts by assuming a fog coating baseline for
all SIM parts. This baseline assumes that SIM parts receive 0.5 mils of
coating solids and are coated with an organic-solvent-based coating
containing 15 percent, by volume, solids.
As a result of these calculations, it was found that VOC emissions
from the exterior coating of SIM parts (-550 Mg/yr [600 tons/yr]) will
account for only about 6 percent of the total VOC emissions from exterior
coating of plastic parts for business machines in 1990. The main reason
for this is because more SF parts than SIM parts are coated. Furthermore,
SF parts are coated with a greater film thickness than SIM parts.
Because VOC emissions from exterior coating of SIM parts account for
such a small fraction of the total, the VOC emissions from exterior
coating of SF parts alone were used to estimate nationwide VOC emissions
in Table 7-7 and to estimate the total number of plants.
The total volume of exterior coating consumed was combined with the
model plant parameters in Table 6-1 to derive the number of plants
performing coating.3 The 1985 exterior coating consumption was assumed
to be split equally between small and medium plants (Model Plants A and
B, respectively). At the present time, no large plants are known to be
consuming 388,030 liters (£) (102,507 gallons) per year, so Model Plant C
was excluded from the calculations for 1985.
-1985 exterior coating consumption = 8.14 xlO6 £/yr (2.15 xlO6 gal/yr).
-Number of small plants = 253
-Number of medium plants = 32
-Number of large plants = 0
Values for nationwide emissions from exterior coating of SF (presented
in Table 7-7) were calculated by multiplying the number of plants by the
VOC emissions presented in Table 7-4.
The procedure used above was also used to project the number of
facilities in 1990. The number of existing facilities from 1985 was
held constant, and it was assumed that existing facilities (i.e., facilities
7-3
-------
not covered by the NSPS) absorbed one-third of the growth between 1985
and 1990. It was assumed that one new large facility will be constructed
between 1985 and 1990, and that the remaining volume of coating not
sprayed by the large plant is divided evenly between the new medium and
small plants. The total number of plants and exterior coating consumption
derived by this procedure are as follows:
-1990 total exterior coating consumption = 17.9 xlO6 £/yr
(4.72 xlO6 gal/yr.)
-Total number of small plants = 444
-Total number of medium plants = 56
-Total number of large plants = 1
Values for nationwide emissions from exterior coating in 1985 and
1990 are presented in Table 7-7. These estimates are based on a baseline
exterior coating consumption rate of 8.14 xlO6 £/yr (2.15 xlO6 gal/yr)
by existing facilities in 1985, and consumption rates of 11.4 xlO6 £/yr
(3.01 xlO6 gal/yr) for existing facilities and 6.47 xlO6 £/yr
(1.71 xlO6 gal/yr) for new facilities in 1990. The VOC emission estimate
for 1990 assumes that existing facilities will increase their production
to absorb one-third of the growth in exterior coating of plastic parts
between 1985 and 1990.
7.1.1.2 Nationwide Emissions from EMI/RFI Shielding Coating in 1985
and 1990. Both SF and SIM parts are coated for EMI/RFI shielding at the
same types of facilities which are characterized by the three sizes of
model plants. Therefore, it was assumed that the estimated number of
existing and new facilities presented in the previous section could be
combined with the EMI/RFI coating consumption at each type of plant to
derive a VOC emission estimate for EMI/RFI shielding of plastic parts
for business machines. Emissions estimates for EMI/RFI shielding processes
appear in Table 7-7. These estimates are based on a baseline EMI/RFI
shielding coating consumption rate of 1.69 xlO6 £/yr (0.446 xlO6 gal/yr)
by existing facilities in 1985, and consumption rates of 2.37 xlO6 £/yr
(0.626 xlO6 gal/yr) for existing facilities and 1.34 xlO6 £/yr
(0.354 xlO6 gal/yr) for new facilities in 1990. The VOC emission estimate
for 1990 assumes that existing facilities increase their production to
absorb one-third of the growth in EMI/RFI shielding of plastic parts.
7-4
-------
7.1.2 Other Emissions
Other air emissions that might be affected by the various regulatory
alternatives include nickel particles emitted from spraying of nickel-
filled EMI/RFI shielding coatings, aluminum oxide particles from grit
blasting prior to zinc-arc spraying, and zinc oxide fumes from zinc-arc
spraying operations. Dry filters and water walls in spray booths often
have particulate removal efficiencies in excess of 99 percent; therefore,
the air impacts of the regulatory alternatives on emissions of nickel
particles, aluminum oxide particles, zinc particles, and zinc oxide
fumes are expected to be minor.
7.2 WATER POLLUTION IMPACT
Processes in plastic parts surface coating facilities that use
water are waterwash spray booths and dip tanks for electro!ess plating.
Waterwash spray booths are equipped with a water curtain that removes
overspray particles from the spray booth exhaust. Water pollution
results from the dissolution of soluble overspray components into the
water. Most of the insoluble material is collected as sludge, but some
of this material is dispersed in the water. The types of water pollutants
likely to result from spray coating operations include organic solvents,
resins, pigments such as lead chromates and titanium dioxide, nickel
particles from EMI/RFI shielding coatings, and zinc from zinc-arc spraying.
Water pollution from coating facilities employing electroless
plating tanks for EMI/RFI shielding results from dragout. Dragout is
defined as the volume of solution carried over the edge of a process
tank by an emerging piece of work. This solution usually ends up in the
water used to clean the application area, or in process drains. Examples
of water pollutants emitted from plating processes are sulfuric acid and
nickel and chromium compounds.
Only the State of Wisconsin has specific regulations for the electro-
plating industry. The Wisconsin Administrative Code, Chapter NR 260,
establishes effluent limitations, standards of performance, and pretreatment
standards for discharge by electroplaters. Federal water pollution
regulations for this and other industries are governed by the Water
Pollution Control Act. This Act specifies several levels of control:
7-5
-------
1. For existing plants, best practical control technology currently
available (BPCTCA/BPT) by 1977.
2. For existing plants, best available technology economically
achievable (BATEA/BAT) by 1983.
3. For new sources, new source performance standards (NSPS)
considering costs and any nonwater quality environmental impact and
energy requirements. The Act allows States to establish more stringent
control levels than Federal standards if desired.
Methods currently employed by the coating industry to handle
wastewater and sludge include discharging to a sanitary sewer, recycling,
incineration, and hauling to a licensed disposal site.
Methods that facilities can employ to reduce water pollution include:
improving transfer efficiencies, the use of dry filter spray booths, and
in-plant controls. Air-assisted airless and electrostatic spray methods
reduce overspray and, thus, can decrease the volume of wastewater from
waterwash spray booths. Use of dry filter spray booths instead of
waterwash spray booths will reduce the amount of wastewater but increase
the amount of solid waste generated by a plant. Examples of in-plant
controls include separation of process and nonprocess water and reusing
and recyling water.
7.3 SOLID WASTE DISPOSAL IMPACT
The majority of solid waste generated by the surface coating process
is produced by coating overspray collected by dry filter and waterwash
spray booths. Solid waste is usually in the form of dirty filters from
dry filter spray booths and sludge from waterwash spray booths. Methods
that are commonly used to dispose of solid wastes include hauling to a
licensed disposal site and incineration. Dried coating solids can be
treated as nonhazardous wastes and disposed of in landfills.
Solid waste impacts of the regulatory alternatives are outlined in
Table 7-8 for each of the model plants. It is evident from this table
that Regulatory Alternatives 1-25/40 through XVI-25/40 reduce the volume
of solid waste generated by the model plants by. 25 percent. These
regulatory alternatives represent improved average transfer efficiency
for prime and color exterior coating; therefore, the solid waste created
7-6
-------
by overspray is reduced. Regulatory alternatives that only use zinc-arc
spray for EMI/RFI shielding also-reduce solid waste production. This
reduction is based on the assumption that zinc overspray will be recovered
and sold by coaters.
Solid waste generated by the model plants can be extrapolated to
estimate the nationwide solid waste disposal impact of the regulatory
alternatives. Regulatory alternatives that call for 40-percent transfer
efficiency for prime and color exterior coating provide a nationwide
solid waste emission reduction of 11 percent from facilities that surface
coat plastic parts for business machines.
7.4 ENERGY IMPACT
Because coatings for plastic business machine parts must cure at a
low temperature to avoid damaging the plastic, the energy consumption
for this process is lower than for similar metal coating processes.
Many of the organic-solvent-based coatings used on plastic business
machine parts can be cured at room temperature. Most organic-solvent-
based coating manufacturers recommend a baking schedule to achieve
optimum finish quality. Waterborne coatings generally require a low
temperature oven cure. However, most coaters use low temperature ovens
to speed up production regardless of the types of coatings used. Some
coaters feel that increased oven air flows, and even intermediate baking
between coats, are necessary to produce an acceptable finish with water-
borne coatings.4 Regulatory alternatives that require the exclusive use
of waterborne exterior coatings or waterborne EMI/RFI shielding coatings
might increase energy consumption at some surface coating plants, due to
the use of higher air flow rates or longer curing times. However,
waterborne coatings are cured at temperatures which are in the range of
50° to 60°C (125° to 140°F) similar to those used for organic-solvent-
based coatings. Therefore, the energy impact of the regulatory alter-
natives specifying waterborne coatings is expected to be negligible.
7.5 OTHER ENVIRONMENTAL IMPACTS
Some of the regulatory alternatives may have impacts on the health
and safety of workers at surface coating plants. Worker exposure to
some of the materials used in the surface coating process must be
7-7
-------
controlled through the use of respirators and proper ventilation. The
use of some of these substances could be affected by the regulatory
alternatives. Examples of hazardous materials that might be affected by
the regulatory alternatives are listed in Table 7-9.
Regulatory alternatives that specify the use of waterborne coatings
could reduce worker exposure to organic solvents and isocyanates. Fire
hazards could also be reduced by use of waterborne coatings.
Regulatory alternatives that specify non-VOOemitting EMI/RFI
shielding methods could reduce worker exposure to organic solvents and
nickel particles present in nickel-filled EMI/RFI shielding coatings;
however, other occupational hazards are associated with non-VOOemitting
EMI/RFI shielding methods. Zinc-arc spray operators must be protected
from zinc oxide fumes and noise. Electro!ess plating techniques employ
acids and soluble nickel and chromium compounds that are toxic. The
EMI/RFI shielding options presented in the regulatory alternatives have
different types of health risks associated with them, so none of them
can be singled out as having the greatest impact on worker safety and
health.
7.6 OTHER ENVIRONMENTAL CONCERNS
7.6.1 Irreversible and Irretrievable Commitment of Resources
For many of the regulatory alternatives, additional equipment will
be required. Manufacturing such equipment will consume steel and other
raw materials. However, consumption of resources for this purpose will
be small compared to the national usage of each resource.
7-8
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33

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Total emissions 84.
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exterior (1
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Higher solids 40
exterior
Waterborne exterior 12.6
CO CM
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Lower solids EHI/RFI 85 t
(
Medium solids EMI/RFI 75
Waterborne EMI/RFI 20
o o
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m in
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ss
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Total emissions 2
(2.
7-13
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•o
OJ
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u
co
UJ
ca
«^ CM CM •— •
§O O CD O CD
0 00 00
OO 00 00

r- m o CD o o
10 P*. O O O O
cn«r oo oo
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O O O O **H 10
O O O O OO CO
o o o o mm
§o o cn o CD
o oo cn CD o
O O UD CO O O
•^ CM CM »-*
p- m CD o CD o
10 P- CD CD O O
cn "t- o o o o
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CD CD O CD O O
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O O O CO CO

§o o cn o CD
0 cocn oo
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v-r CMCM ^
p— in CD o o o
10 P— CD O CD CD
Lower solids EHI/RFI 49
(54
Medium solids EMI/RFI 0
(0
Waterbone EMI/RFI 0
(0
0
oo

rH U3
OO CO

oen
co cn
10 CO
CM CM
gg
o o
i— • m
cn *r
«r in
rH 10
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co cn
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CM CM
00
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«r m
rH 10
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oo cn
CM CM
P-. in
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r- in
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cn o-
-------
TABLE 7-4. SUMMARY OF ANNUAL VOC EMISSIONS FROM MODEL
PLANTS, A, B, AND C FOR EACH REGULATORY ALTERNATIVE

Reg. Alt.
1-25
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
XIII-25
XI V-25
XV-25
XVI-25
1-25/40
11-25/40
111-25/40
IV-25/40

EMI/RFI
coating
emissions
2.48
(2.74)
1.31
(1.45)
0.27
(0.29)
0.00
(0.00)
2.48
(2.74)
1.31
(1-45)
0.27
(0.29)
2.48
(2.74)
0.00
(0.00)
1.31
(1.45)
0.27
(0.29)
2.48
(2.74)
0.00
(0.00)
1.31
(1.45)
0.27
(0.29)
0.00
(0.00)
2.48
(2.74)
1.31
(1.45)
0.27
(0.29)
0.00
(0.00)

Model Plant
Exterior
coating
emissions
8.12
(8.95)
8.12
(8.95)
8.12
(8.95)
8.12
(8.95)
4.82
(5.31)
4.82
(5.31)
4.82
(5.31)
3.28
(3.62)
4.82
(5.31)
3.28
(3.62)
3.28
(3.62)
1.78
(1.96)
3.28
(3.62)
1.78
(1.96)
1.78
(1.96)
1.78
(1.96)
6.60
(7.27)
6.60
(7.27)
6.60
(7.27)
6.60
(7.27)
VOC emissions, Mq/yr (ton/yr)
A Model Mant 6
Total
emissions
10.61
(11.69)
9.44
(10.40)
8.39
(9.25)
8.12
(8.95)
7.30
(8.05)
6.13
(6.76)
5.08
(5.60)
5.76
(6.35)
4.82
(5.31)
4.60
(5.07)
3.55
(3.91)
4.26
(4.70)
3.28
(3.62)
3.09
(3.41)
2.04
(2.25)
1.78
(1.96)
9.08
(10.01)
7.91
(8.72)
6.86
(7.57)
6.60
(7.27)
EMI/RFI
coating
emissions
19.86
(21.90)
10.52
(11.59)
2.12
(2.34)
0.00
(0.00)
19.86
(21.90)
10.52
(11.59)
2.12
(2.34)
19.86
(21.90)
0.00
(0.00)
10.52
(11-59)
2.12
(2.34)
19.86
(21.90)
0.00
(0.00)
10.52
(11.59)
2.12
(2.34)
0.00
(0.00)
19.86
(21.90)
10.52
(11.59)
2.12
(2.34)
0.00
(0.00)
Exterior
coating
emissions
64.98
(71.63)
64.98
(71.63)
64.98
(71.63)
64.98
(71.63)
38.54
(42.49)
38.54
(42.49)
38.54
(42.49)
26.26
(28.94)
38.54
(42.49)
26.26
(28.94)
26.26
(28.94)
14.23
(15.69)
26.26
(28.94)
14.23
(15.69)
14.23
(15.69)
14.23
(15.69)
52.80
(58.20)
52.80
(58.20)
52.80
(58.20)
52.80
(58.20)
Total
emissions
84.85
(93.53)
75.50
(83.22)
67.11
(73.97)
64.98
(71.63)
58.41
(64.38)
49.06
(54.08)
40.67
(44.83)
46.12
(50.84)
38.54
(42.49)
36.77
(40.53)
28.38
(31.28)
34.10
(37.59)
26.26
(2S.-94)
24.75
(27.28)
16.36
(18.03)
14.23
(15.69)
72.66
(80.10)
63.32
(69.79)
54.92
(60.54)
52.80
(58.20)

Model Plant C
EMI/RFI
coating
emissions
49.67
(54.75)
26.30
(28.99)
5.31
(5.86)
0.00
(0.00)
49.67
(54.75)
26.30
(28.99)
5.31
(5.86)
49.67
(54.75)
0.00
(0.00)
26.30
(28.99)
5.31
(5.86)
49.67
(54.75)
0.00
(0.00)
26.30
(28.99)
5.31
(5.86)
0.00
(0.00)
49.67
(54.75)
26.30
(28.99)
5.31
(5.86)
0.00
(0.00)
Exterior
coating
emissions
162.40
(179.02)
162.40
(179.02)
162.40
(179.02)
162.40
(179.02)
96.33
(106.18)
96.33
(106. 18)
96.33
(106.18)
65.62
(72.33)
96.33
(106.18)
65.62
(72.33)
65.62
(72.33)
35.58
(39.22) |
65.62 :
(72.33) ;
35.58 i
(39.22) i
35.58
(39.22)
35.58
(39.22)
131. 95
(145.45)
131.95
(145.45)
131.95
(145.45)
131.95
(145.45)
. Total
emissions
212.07
(233.77)
188. 70
(208.00)
167.72
(184.87)
162.40
(179.02)
146.00
(160.93)
122.63
(135.17)
101.64
(112.04)
115.29
(127.08)
i96.33
(106.18)
:' 91.92
(101.32)
/ 70.93
/ (78.19)
85.25
(93.97)
65.62
(72.33)
61.87
(68.20)
40.39
(45.07)
35.58
(39.22)
181.62
(200.20)
158.25
(174.44)
: 137.27
{151.31)
',131.95
(145.45)
(continued)
7-15
-------

Reg. Alt.
V-Z5/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40
X-2S/40
XI-25/40
XI 1-25/40
XIII-25/40
XIV-25/40
XV-25/40
XVI-25/40

EHI/RFI
coating
emissions
2.48
(2.74)
1.31
(1.45)
0.27
(0.29)
2.48
(2.74)
0.00
(0.00)
1.31
(1.45)
0.27
(0.29)
2.48
(2.74)
0.00
(0.00)
1.31
(1.45)
0.27
(0.29)
0.00
(0.00)

lodel Plant
Exterior
coating
emissions
3.91
(4.31)
3.91
(4.31)
3.91
(4.31)
2.67
(2.94)
3.91
(4.31)
2.67
(2.94)
2.67
(2.94)
1.45
(1.59)
2.67
(2.94)
1.45
(1.59)
1.45
(1.59)
1.45
(1.59)
TABLE
7-4. (continued)
VOC emissions, Mg/yr (ton/yr)
A
Total
emissions
6.40
(7.05)
5.23
(5.76)
4.18
(4.61)
5.15
(5.68)
3.91
(4.31)
3.98
(4.39)
2.93
(3.23)
3.93
(4.33)
2.67
(2.94)
2.76
(3.04)
1.71
(1.89)
1.45
(1.59)

EMI/RFI
coating
emissions
19.86
(21.90)
10.52
(11.59)
2.12
(2.34)
19.86
(21.90)
0.00
(0.00)
10.52
(11.59)
2.12
(2.34)
19.86
(21.90)
0.00
(0.00)
10.52
(11.59)
2.12
(2.34)
0.00
(0.00)
todel Plant
Exterior
coati ng
emissions
31.32
(34.52)
31.32
(34.52)
31.32
(34.52)
21.33
(23.52)
31.32
(34.52)
21.33
(23.52)
21.33
(23.52)
11.57
.(12.75)
21.33
(23.52)
11.57
(12.75)
11.57
(12.75)
11.57
(12.75)
B
Total
emissions
51.18
(56.41)
, 41.83
(46.11)
33.44
(36.86)
41.20
(45.41)
31.32
(34.52)
31.85
(35.11)
23.46
(25.86)
31.43
(34.64)
21.33
(23.52)
22.08
(24.34)
13.69
(15.09)
11.57
(12.75)
i
1
1

. Model Plant C
EMI/RFI
coating
emissions
49. 67
(54.75)
26.30
(28.99)
5.31
(5.86)
49.67
(54.75)
0.00
(0.00)
26.30
(28.99)
5.31
(5.86)
49.67
(54.75)
0.00
(0.00)
26.30
(28.39)
5. '31
. (5:86)
d.oo
(0.00)
Exterior
coating
emissions
78.26
(86.27)
78.26
(86.27)
78.26
(86.27)
53.32
(58.77)
78.26
(86.27)
53.32
(58.77)
53.32
(58.77)
28.91
(31.86)
53.32
(58.77)
28.91
(31.86)
28.91
(31.86)
28.91
(31.86)
Total
emissions
127.94
(141.02)
104.56
(115.26)
83.58
(92.13)
102.99
(113.52)
78.26
(86.27)
79.61
(87.76)
58.63
(64.63)
78.58
(86.62)
53.32
(58.77)
55.20
(60.85)
34.22
(37.72)
28.91
(31.86)
Shielding is p«rformed by a non-VOC-emitting process.
7-16
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7-18
-------
TABLE 7-7. TOTAL NATIONWIDE-EMISSIONS FROM THE COATING OF PLASTIC
PARTS FORfBUSINESS MACHINES
: Mg/yr (tons/yr)
1985 Emissions ' Total 1990 emissons
Reg. Alt.
1-25
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
XIII-25
XIV-25
XV-25
XVI-25
1-25/40
11-25/40
111-25/40
IV-25/40
EHI/RFI Exterior , EMI/RFI
coating coating Total coating
emissions emissions emissions emissions
1,264 4,134 5,398 2,772
(1,393) (4,557) (5,951) (3,055)
2,301
(") (") (--) (2,536)
1,878
(--) ( — ) (— ) (2,070)
1,771
(") (--} (—) (1,952)
2,772
(") C— ) (") (3,055)
2,324
(--) (—) (--) (2,562)
1,878
(--) (") (— ) (2,070)
2,772
(") (") ;(") (3,055)
1,771
(--) (") i(~) (1,952)
: ~ 2,301
(--) (--) ,' (") (2,536)
; -- 1,878
(--} (— ) (") (2,070)
: — 2,772
{--) (") (") (3,055)
1,771
(--) (— ) (— ) (1.952)
2,301
(— ) (--) ( — ) (2,536)
1,878
(--) (— ) (--) (2,070)
1,771
(--) ( — ) (") (1,952)
2,772
(") ( — ) (") (3,055)
2,301
(--) (") ; (") (2,536)
1,878
(") (— ) (— ) (2,070)
' — 1>771
(") (") (") (1,952)
Exterior
coating
emissions
9,067
(9,995)
9,067
(9,995)
9,067
(9,995)
9,067
(9,995)
7,735
(8,526)
7,735
(8,526)
7,735
(8,526)
7,116
(7,844)
7,735
(8,526)
7,116
(7,844)
7,116
(7,844)
6,511
(7,177)
7,116
(7,844)
6,511
(7,177)
6,511
(7,177)
6,511
(7,177)
8,453
(9,318)
8,453
(9,318)
8,453
(9,318)
8,453
(9,318)
Total
emissions
11,839
(13,050)
11,368
(12,531)
10,945
(12,065)
10,838
(11,947)
10,507
(11,582)
10,059
(11,088)
9,613
(10,597)
9,888
(10,899)
9,506
(10,479)
9,417
(10,380)
8,994
(9,914)
9,282
(10,232)
8,887
(9,796)
8,811
(9,713)
8,389
(9,247)
8,282
(9,129)
11,225
(12,373)
10,754
(11,854)
10,331
(11,388)
10,224
(11,270)
Emissions in 1990
NSPS affected facilities
EMI/RFI
coating
emissions
1,001
(1,103)
530
(584)
107
(118)
0
(0)
1,001
(1,103)
553
(610)
107
(118)
1,001
(1,103)
0
(0)
530
(584)
107
(118)
1,001
(1,103)
0
(0)
530
(584)
107
(118)
0
(0)
1,001
(1,103)
530
(584)
107
(118)
0
(0)
Exterior
coating
emissions
3,273
(3,608)
3,273
(3,608)
3,273
(3,608)
3,273
(3,608)
1,941
(2,140)
1,941
(2,140)
1,941
(2,140)
1,323
(1,458)
1,941
(2,140)
1,323
(1,458)
' 1,323
(1,458)
717
(790)
1,323
(1,458)
717
(790)
717
(790)
717
(790)
2,660
(2,932)
2,660
(2,932)
2,660
(2,932)
2,660
(2,932)
Total
emissions
4,274
(4,711)
3,803
(4,192)
3,380
(3,726)
3,273
(3,608)
2,942
(3,243)
2,495
(2,750)
2,048
(2,258)
2,323
(2,561)
1,941
(2,140)
1,852
(2,042)
1,430
(1,576)
1,718
(1,893)
1,323
(1,458)
1,247
(1,374)
824
(908)
717
(790)
3,660
(4,035)
3,189
(3,516)
2,767
(3,050)
2,660
(2,932)
(continued)
7-19
-------
TABLE 7-7. (continued)
Reg. Alt.
1985 Emissions
Total 1990 emissons
Emissions in 1990
NSPS affected facilities
EMI/RFI Exterior
coating coating Total
emissions emissions emissions
EMI/RFI
coating
emissions
Exterior
coating
emissions
Total
emissions
EMI/RFI
coating
emissions
Exterior
coating Total
emissions emissions
V-25/40
VI-25/40
VI 1-25/40
VIII-25/40
IX-25/40
X-25/40
XI-25/40
XII-25/40
XIII-25/40
XIV-25/40
XV-2S/40
XVI-25/40
2,772
(-) ' (--) (") (3,055)
2,324
(--) (— ) (") (2,562)
1,878
(--) (--) (-- ) (2,070)
2,772
(--) (--) (-) (3,055)
1,771
(--) (--) (-) (1.952)
2.301
(--) {--) (") (2,536)
1,878
(--) (--) (— ) (2,070)
2,772
(--) (") (") (3,055)
1,771
(--) (--) (") (1,952)
2,301
(--) (-) (") (2,536).
— . — — 1,878 .
(--) (—) (--) (2,070)
1,771
(--) (--) (") (1,952)
7,371
(8,125)
7,371
(8,125)
7,371
(8,125)
6,868
(7,571)
7,371
(8,125)
6,868
(7,571)
6,868
(7,571)
6,376
(7,029)
6,868
(7,571)
6,376
(7,029)
6.376
(7,029)
6,376
(7,029)
10,143
(11,180)
9,695
(10,687)
9,249
(10,195)
9,640
(10,626)
9,142
(10,077)
9,169
(10,107)
8,746
(9,641)
9,148
(10,084)
8,639
(9,523)
8,677
(9,565)
8,254
(9,099)
8,147
(8,981)
1,001
(1,103)
553
(610)
107
(118)
1,001
(1,103)
0
(0)
530
(584)
107
(118)
1,001
(1,103)
0
(0)
530
(584)
107
(118)
0
(0)
1,577
(1,739)
1,577
(1,739)
1,577
(1,739)
1,075
(1,184)
1,577
(1,739)
1,075
(1,184)
1,075
(1,184)
583
(642)
1,075
(1.184)
583
(642)
583
(642)
583
(642)
2,578
(2,842)
2,131
(2,348)
1,684
(1,857)
2,075
(2,288)
1,577
(1,739)
1,604
(1,768)
1,182
(1,302)
1,583
(1,745)
1,075
(1,184)
1,112
(1,226)
690
(760)
583
(642)
*A11 values were calculated in metric units and converted into English units using
1 aegagram (Hg) equals 1.1023 tons.
the conversion factor
7-20
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7-22
-------
7.7 REFERENCES FOR CHAPTER 7
1.
2.
3.
Memo from Valiente, L., RTI, to Jenkins, R., and D. Salman, EPA, and
D. Newton, MRI. August 1, 1984. Projected real growth rate of
plastic business machine parts through 1990.
Plastics in Business Machines Growing.
July 1982.
Plastics World. 40:10.
Memo from Duletsky, B., J. Larson, and D. Newton, MRI, to the Project
File. September 12, 1984. Calculation of the number of structural
foam spray coating facilities covered by an NSPS.
4. Von Hor, R. C. The Processor's View of Relative Costs of the New
Technology Paints for Structural Foam Products, Ex-Cell-0 Corpora-
tion, Athens, Tennessee. (Presented at the SPI Structural Foam
Conference. Atlanta. April 18-20, 1983). 23 p.

5. TLV Threshold Limit Values for Chemical Substances in the Work
Environment Adopted by ACGIH for 1983-84. American Conference of
Governmental Industrial Hygienists. 1983. pp. 10-35.

6. U.S. Occupational Safety and Health Administration. Code of Federal
Regulations. Title 29, Chapter XVII, Subpart Z, Section 1910.1000.
Washington, D.C. Office of the Federal Register. March 11, 1983_.

7. U.S. Department of Health, Education, and Welfare, National Institute
for Occupational Safety and Health. Criteria for a Recommended
Standard . . . Occupational Exposure to Inorganic Nickel. NHEW
(NIOSH) publication No. 77-164. U.S. Government Printing Office,
Washington, D.C. May 1977. 282 pages.
7-23
-------
-------
8. COSTS

8.1 COST ANALYSIS OF REGULATORY ALTERNATIVES
The estimated cost impacts of implementing the regulatory alternatives
for the model plants described in Chapter 6 are presented in this chapter.
The objective of this analysis is to quantify the cost impacts associated
with various levels of control of VOC emissions. The economic impact of
the regulatory alternatives on surface coaters of plastic parts for
business machines is presented in Chapter 9.
Capital and annualized costs are presented for each regulatory
alternative. All costs are presented in January 1984 dollars.
8.1.1 New Facilities
Three model plants [small (A), medium (B), and large (C)] have been
defined to include the major equipment and techniques now being used to
surface coat plastic parts for business machines. The model plants are
intended to reflect surface coating facilities expected to be built in
the future including in-house coating operations of business machine
manufacturers, contractors who perform both molding and coating of
plastic parts, or job shops performing coating services only. These
model plants, presented in Table 8-1, were developed on the basis of
data gathered from industry and published literature. A model plant is
defined as a combination of a coating application/flashoff area, drying
oven(s), and the auxiliary equipment. Table 8-1 presents the baseline
parameters for model plants A, B, and C, which were used for- all emissions
and cost calculations. The baseline, Regulatory Alternative I, reflects
the level of emission control in the absence of an NSPS.
Capital investment and annual operating and maintenance (O&M) costs
were calculated for all the regulatory alternatives for each model plant
8-1
-------
size. The cost calculations were performed using information supplied
by coaters, coating and equipment vendors, and various published works.1-5
8.1.1.1 Capital Costs—Model Plants. Tables 8-2 and 8-3 show the
basis for estimating capital costs for the model plants for each regulatory
alternative. Table 8-2 shows the estimated costs given by industry for
the conveyors (if used), spray equipment, spray booths, associated
ovens, and'auxiliary equipment. Land and building costs, based on
purchased equipment costs, were also included in the capital cost estimates.
Table 8-3 shows the installed costs for the three model plants at baseline
conditions.
8.1.1.2 Annualized Costs—Model Plants. Table 8-4 shows the basis
for estimating annualized costs for the model plants including the cost
of the eight coatings specified in the regulatory alternatives. Table 8-5
presents the methods for calculating direct and indirect annualized
operating costs. Table 8-6 shows the annualized cost estimates for the
three model plants at baseline conditions, including indirect operating
costs.5
8.1.1.3 Cost Effectiveness. The cost-effectiveness value is the
annual dollar cost to control 1 megagram (ton) of VOC pollutant. The
average cost-effectiveness value of each alternative was calculated by
dividing the annual ized cost with respect to baseline by the annual VOC
emission reduction.
Tables 8-7, 8-8, and 8-9 how the average cost effectiveness values
of the regulatory alternatives for model plants A, B, and C, respectively.
These tables also show the total annual ized cost and the cost with
respect to baseline values for all the regulatory alternatives.
As shown in Table 8-7, for a small plant (model plant A), the
average cost effectiveness values range from $-20,000/Mg ($-18,000/ton)
for Regulatory Alternative 1-25/40 to $72,000/Mg ($66,000/ton) for Regulatory
Alternative IV-25.
As shown in Table 8-8, for a medium plant (model plant B), the
average cost effectiveness values range from $-14,000/Mg ($-13,000/ton)
for Regulatory Alternative 1-25/40 to $14,000/Mg ($13,000/ton) for Regulatory
Alternative 11-25.
8-2
-------
As shown in Table 8-9, for a large plant (model plant C), the
average cost effectiveness values range from $-14,000/Mg ($-13,000/ton)
for Regulatory Alternative 1-25/40 to $14,000/Mg ($13,000/ton) for Regulatory
Alternative 11-25.
8.1.2 Modified/Reconstructed Facilities
Under the provisions of 40 CFR 60.14 and 60.15, an "existing facility"
may become subject to standards of performance if it is modified or
reconstructed. As a result of such actions, the facility would incur
certain costs or savings from the conversion to the mode of operation
necessary to achieve the proposed standard. Presented in Table 8-2 are
the cost elements for estimating installed capital costs for a modified
or reconstructed facility. Table 8-4 presents the cost elements for
estimating direct operating costs for such a facility, and Table 8-5
presents the methods used for calculating annualized costs for such a
facility.
8.2 OTHER COST CONSIDERATIONS
In addition to costs as-sociated with the Clean Air Act, the surface
coating industry may also incur costs as a result of other Federal rules
or regulations. These impacts are discussed in this section.
8.2.1 Costs Associated with Increased Water Pollution and Solid Waste
Disposal
Wastewater disposal costs arise from the wastewater generated by
waterwash spray booths and by cleanup operations. Paint solids, organic
solvents, and zinc solids are the primary water pollutants. Solids are
skimmed or settled out of the wastewater before it is disposed'of in a
municipal sewer system. Costs for disposal of paint solids in a secure
landfill or by incineration are also included in annual costs. The
resale value of recovered zinc is included as a credit, according to the
current market value of zinc. Other solid wastes include used filters
from dry filter spray booths and materials associated with the cleanup
of the spray areas. Costs for disposal of these wastes were also included
in the annual costs. Annual costs for maintenance include labor used
for booth clean-up.
8-3
-------
8.2.2 Resource Conservation and Recovery Act
Solid v/aste generated by the surface coaters of plastic parts for
business machines is not currently classified as hazardous or toxic
under the provisions of the Resource Conservation and Recovery Act
(RCRA). However, because many coaters are currently disposing of paint
sludges by incineration or by burial in a secure sanitary landfill,
costs are calculated for disposal by these methods.
8.2.3 Occupational Safety and Health Administration Act
The cost of protective equipment required for zinc-aric spraying
was included in the estimated capital cost to industry for each of the
regulatory alternatives. However, no data were obtained regarding any
additional cost to industry of compliance with the Occupational Safety
and Health Administration Act (OSHA).
8.2.4 Resource Requirements Imposed on State, Regional, and Local Agencies
The owner or operator of a surface coating facility is responsible
for making application to the State for a permit to construct and
subsequently operate a new installation. The review of the applications,
and any later enforcement action, would be handled by local, State, or
regional regulatory agencies. Since it is projected that 216 plants
will be subject to an NSPS in 1990 and that these plants will be scattered
throughout the United States, the promulgation of standards for the
surface coaters of plastic parts for business machines should not impose
major resource requirements on the regulatory agencies.
8-4
-------
TABLE 8-1. MODEL PLANT PARAMETERS
a,b
Parameter
A. Production
1. Total volume of coating used at
Plant A Plant B Plant C
19,409 (5,127) 155,202 (41,000) 388,030 (102,507)
11.
iii.
capacity, 2/yr (gal/yr)

2. Total solids sprayed, £/yr (gal/yr)

3. Total solids applied, Z/yr (gal/yr)c

B. Operating Parameters

1. Period of Operation
a. h/d
b. d/wk
c. wk/yr

C. Process Parameters

1. Type and amount of coatings used
at baseline emission level
a. Solvent-based nickel-filled
acrylic for EHI/RFI shielding
containing 15%, by volume, solids
at the gun (17.1% of total coating
consumption)
i. Volume of coating sprayed,
Z/yr (gal/yr)
Volume of VOC sprayed,
Z/yr (gal/yr)
Volume of solids applied,
A/yr (gal/yr)
Solvent-based two-component
catalyzed urethane containing 32%,
by volume, solids at the gun (53.7%
of total coating consumption)
i. Volume of coating sprayed,
i/yr (gal/yr)
Volume of VOC sprayed,
Z/yr (gal/yr)
Volume of solids applied,
Z/yr (gaVyr)c
c. Solvent-based two-component
catalyzed urethane containing
50%, by volume, solids at the gun
(19.5% of total coating consump-
tion)
i. Volume of coating sprayed,
Z/yr (gal/yr)
ii. Volume of VOC sprayed,
Z/yr (gal/yr)
iii. Volume of solids applied,
Z/yr (ga]/yr)c
d. Waterborne acrylic containing 37%,
by volume, solids at the gun, and
12.6%, by volume, organic solvent
at the gun (9.7% of total coating
consumption)
i. Volume of coating sprayed,
Z/yr (gal/yr)
ii. Volume of VOC sprayed,
Z/yr (gal/yr)
Volume of solids applied,
Z/yr (gal/yr)c
ii.

iii.
6,420 (1,696) 51,368 (13,570)

1,730 (457) 13,836 (3,655)
16
5
50
16
5
50
3,331 (880)

2,831 (748)

250 (66)
26,498 (7,000)

22,523 (5,950)

1,987 (525)d
10,410 (2,750) 83,279 (22,000)

7,079 (1,870) 56,630 (14,960)

833 (220) 6,662 (1,760)
3,785 (1,000) 30,283 (8,000)

1,893 (500) 15,142 (4,000)

473 (125) 3,785 (1,000)
m.
1,882 (497) 15,142 (4,000)

237 (63) 1,908 (504)

174 (46) 1,401 (370)
128,424 (33,926)

34,591 (9,138)
16
5
50
66,270 (17,507)

56,329 (14,881)

4,970 (1,313)°
208,198 (55,000)

141,574 (37,400)

16,656 (4,400)
75,708 (20,000)

37,854 (10,000)

9,464 (2,500)
37,854 (10,000)

4,770 (1,260)

3,502 (925)
(continued)
8-5
-------
TABLE 8-1. (continued)
Parameter
Plant A
Plant B
Plant C
2.
3.
4.
Zinc consumption for zinc-arc
EMI/RFI shielding

a. Total zinc sprayed, kg/yr (Ib/yr)
b. Zinc solids applied, kg/yr (Ib/yr)

Coating equipment
a. Conveyor!zed lines
b. Manual air atomized spray guns
c. Dry filter spray booths
d. Waterwash spray booths
e. Spray booth ventilation rate, m3/s
(acfra) f
f. Grit blasting booths
g. Zinc-arc spray booths9
h. Gas-fired intermediate bake ovens
i. Gas-fired final curing ovens
Coating application
a. Average transfer efficiency
i. Prime and color coats
ii. Texture and touch-up coats
iii. • EHI/RFI nickel-filled
shielding coat
b. Average dry film thickness for
EHI/RFI shielding coats
i. Metal-filled coatings
ii. Zinc-arc spray
c. Average dry film thickness for
exterior coats
i. Prime/filler coat
ii. Color coat
iii. Texture coat
iv. Total exterior film thickness
applied
d. Average flash-off period
i. EMI/RFI shielding
ii. Prime/filler coat
iii. Color coat
iv. Texture coat
e. Curing temperature and time in
intermediate bake oven
i. Prime/filler coat
ii. Color coat
f. Curing temperature and time 140°F
in final curing oven
g. Average conveyor speed, m/s
(ft/rain)
0 65,305 (144,101) 130,517 (288,000)
0 34,612 (76,374) 69,174 (152,640)
0
2
2

1
5
5
(2 batch; 3 on
conveyorized line)

4.7
(10,000)
0
0
0

•
25%
25%
50%
2 mil
3 mil
' 2 mil
1 milh
3 milh
6 mil
Variable
Variable
Variable
Variable
N/A1
N/A
for 30 min

4.7
(10,000)
2
2
0

2
(1 batch oven;
1 multiple pass
oven on
conveyorized line)
25%
25%
50%
2 mil
3 mil
2 mil
1 mil.
3 milh
6 mil
12 min
12 min
12 min
12 min
N/A
N/A
140°F for 30 min
2
9
6
(2 batch; 4 on
conveyorized
line No. 1)
3
(3 on conveyorized
line No. 2)
4.7
(10,000)
4
4
1
(Conveyorized line
No. 2)
2
(1 batch oven;
1 multiple pass
oven through which
both conveyor
lines pass)
25%
25%
50%
2 mil
3 mil
2 mil
1 milh
3 mil
6 mil
12 min
12 min
12 min
12 min
120°F for 10 min
120°F for 10 min
140°F for 30 min
N/A
0.04 (8)
0.04 (8)
(continued)
8-6
-------
TABLE 8-1. (continued)
Parameter
0. VOC Emissions
1. Total solvent (VOC) emissions,
Mg/yr (t/yr)
a. Percent VOC emissions from spray
booths
b. Percent VOC emissions from flash-off
areas
c. Percent VOC emissions from ovens
Plant A

10.6 (11.7)
80

10
Plant B

85 (94)
80

10
Plant C

212 (234)
80

Spray equipment
Air spray (gun, pump and hoses)
Air-assisted/airless spray (gun, pump, and hoses)
Electrostatic spray (gun, pump, and hoses)
Agitator (for metal-filled coatings)
Stainless steel parts (for waterborne coatings)
Proportioning system (for higher solids exterior coatings)
Electrically isolated paint supply (for spraying waterborne
coatings electrostatically)

Dry filter spray booth
Booths, motors and initial filters
Plant A
Plant B
Plant C

Waterwash spray booth
Booth and motor

Zinc-arc spray station
Grit blaster
Zinc-arc sprayer
Waterwash spray booth and motor
Safety helmet and glasses
Total

Direct-fired gas oven
Batch oven (Plants A, B, and C)
Final conveyorized oven (Plant B)
Final conveyorized oven (Plant C)
Intermediate conveyorized oven (Plant C)
90,000
1,200
2,500
4,300
350
100
3,500
600
2 for 7,500
5 for 17,850
6 for 21,000
13,050
13,500
8,800
13,050
900
36,250
20,000
135,000
135,000
135,000
Land and building
(0.53)(purchased
equipment cost)
Based on industry and vendor data, assume average total conveyor length of
b366 m (1,200 ft).
Purchased equipment cost = (total installed equipment cost -f 1.35).
8-8
-------
TABLE 8-4. BASIS FOR ESTIMATING DIRECT OPERATING COSTS FOR SURFACE COATING
OF PLASTIC PARTS USED IN BUSINESS MACHINES5
Cost element
Cost per unit
specified, $
Labor
Operator .
Supervisory
Raw materials0
Organic-solvent-based two-component catalyzed
urethane coating containing 32%, by volume,
solids at the gun
Organic-solvent-based two-component catalyzed
urethane coating containing 50%, by volume,
solids at the gun
Organic-solvent-based two-component catalyzed
urethane coating containing 60%, by volume,
solids at the gun
Waterborne acrylic coating containing 32%, by
volume, solids at the gun
Organic-solvent-based nickel-filled acrylic
EMI/RFI shielding coating containing 15%, by
volume, solids at the gun
Organic-solvent-based nickel-filled urethane
EMI/RFI shielding coating containing 25%, by
volume, solids at the gun
Waterborne acrylic EMI/RFI shielding coating
containing 33%, by volume, solids at the gun
Zinc wire
Zinc wire
Maintenance
Labor
Materials

Utilities6
Electricity
Natural gas f
Waste disposal0'
9.83/person-h
15% of direct
operating labor

18/gal at the gun
25/gal at the gun

35/gal at the gun

20/gal at the gun

32/gal at the gun

85/gal at the gun

90/gal at the gun

1/1 b

9.83/persgn-h
As needed

0.056/kWh
3.13 Mcf
60/55-gal drum
Average of BLS hourly wages
^November 1983 dollars.
p. 3-12.
for SIC codes 3471, 3479, and 3079 in
.Based on GARD manual
dBased on vendor and industry information.
Cost is dependent on size of plant and amount of spray application
equipment.
fAverage of BLS regional utility costs in January
Approximate cost to incinerate or landfill solid
transportation fees.
1984 dollars.
waste. Does not include
8-10
-------
TABLE 8-3. INSTALLED CAPITAL COSTS FOR REGULATORY
ALTERNATIVE 1-25—BASELINE5
Cost item
1.

3.
Equipment costs
Conveyor (1,200 ft/line)
number:
cost, $:
Air spray equipment
Guns, pumps, hoses
number:
cost, $:
Agitator
number:
cost, $:
Stainless steel parts
number:
cost, $:
Dry filter spray booths
number:
cost, $:
Waterwash spray booths
number:
cost, $:
Zinc- arc spray stations
number:
cost, $:
Direct-fired gas ovens
Batch
number:
cost, $:
Conveyorized
number:
cost, $:
Total installed equipment costs, $:
Purchased equipment costs, $:
(total installed 4- 1.35)
Direct costs
Land and building, $:
(0.53)(purchased equipment)
Total installed costs

Plant A

0
0

2
2,400

1
350

1
100

2
7,500

0
0

1
20,000

0
0
30,400
22,500

11,900

42,300
Plant B

1
90,000 -

5
6,000

1
350

1
100

5
17,850

0
0

2
72,500

1
20,000

1
135,000
341,800
253,200

134,200

476,000
Plant C

2
180,000

9
10,800

2
700

1
100

6
21,000

3
39,150

4
145,000

1
20,000

2 •
270,000
686,800
508,700

269,600

956,400
8-9
-------
TABLE 8-5. METHODS FOR CALCULATING ANNUALIZED COSTS FOR PLASTIC PARTS
USED IN BUSINESS MACHINES5
Cost item
Method of calculation
Direct operating costs

Labor3

Operator

Model Plant A
Non-ZA .
alternatives

ZA alternatives0
Model Plant B
Non-ZA
alternatives
ZA alternatives
Model Plant C
Non-ZA
alternatives
ZA alternatives

Supervisor

Raw materials
(1.5 person/booth)(4,000 h/yr)($9.83/person-h)
(No. DF booths)

(1.5 person/booth)(4,OQO h/yr)($9.83/person-h)
(No. DF booths)(1.34a)
(1.5 person/booth)(4,000 h/yr)($9.83/person-h)
(No. DF booths) + (3.5 person/ZA station)
(4,000 h/yr)($9.83/person-h)(No. ZA stations)

(1.5 person/booth)(4,OQO h/yr)($9.83/person-h)
(No. DF booths + l/4e) + (3.5 person/ZA
station)(4,000 h/yr)($9.83/person-h)(No. ZA
stations)
(1.5 person/booth)(4,000 h/yr)($9.83/person-h)
(No. DF + WW booths) + (3.5 person/ZA station)
(4,000 h/yr)($9.83/person-h)(No. ZA stations)

(1.5 person/booth)(4,000fh/yr)($9.83/person-h)
(No. DF + WW booths-lr) + (3.5 person/ZA
station)(4,000 h/yr)($9.83/person-h)(No. ZA
stations)

15% of direct operating labor

See Attachment B of reference 5
(continued)
8-11
-------
TABLE 8-5. (continued)
Cost item
Method of calculation
Maintenance^'

Labor
Materials
[(3.43 person-h/booth/d)(250 d/yr)
($9.83/person-h)(No. DF booths) +
(0.75)($25,000/yr)(No. WW booths)]

[1/TET1 +l1 i [1/2] + ($944/yr)(No. ovens) +
[l/TE2-l J
($27,179.225/yr/ZA station)(No. ZA stations)

[($18.79/day/DF booth)(250 d/yr)
(No. DF booths + No. ZA stations) +
($6,250/yr/WW booth)(No. WW booths +
No. ZA stations)]
Utilities

Electricity^

Natural gas

Waste disposal

Indirect operating costs
(5 hp/booth) (0.7457 kW/hp)(4,000 h/yr)
(No. booths)($0.056/kWh) v 0.90

[(106 ft3 /mo/conveyor i zed oven)(No. conveyorized
ovens) + (10s ft3 /mo/batch oven) (No. batch
ovens)](12 mo/yr)($3.13/Mcf)

1/2[($11,330/DF booth/yr)(No. DF booths +
No. ZA stations)]

+ sludge disposal chargek
.

KEI1"} +1
I/ I t2~-L J

Overhead
Taxes

Insurance
1
Administration
1
Capital recovery
,m
80% of the sum of operating, supervisory, and
maintenance labor

1% of capital costs

2% of capital costs

13.147% of capital costs
(continued)
8-12
-------
TABLE 8-5. (continued)
Labor costs decrease by 33 percent for exterior coating operations for
regulatory alternatives involving the use of higher solids exterior
.coatings.
Regulatory alternatives (-25 and -25/40 alternatives) allowing VOC-emitting
EMI/RFI shielding coatings: I, II, III, V, VI, VII, VIII, X, XI, XII, XIV,
and XV.
Regulatory alternatives (-25 and -25/40 alternatives) requiring
dnon-VOC-emitting EMI/RFI shielding coatings: IV, IX, XIII, and XVI.
Reflects 17 percent drop in labor due to elimination of spraying metal-
filled EMI/RFI shielding coatings and 51 percent (3 x 17 percent) increase
gin labor due to extra manpower required for zinc-arc spray operations.
Reflects extra labor required due to the increase in production rate per
fDF booth.
Reflects decrease in labor required due to elimination of spraying metal-
filled EMI/RFI shielding coatings.
9Includes maintenance costs for booths and ovens. Booth maintenance
decreased by 25 percent for regulatory alternatives using improved
•transfer efficiency.
These equations apply to non-ZA alternatives. For ZA alternatives,
maintenance labor and materials is adjusted in the same manner as
operator and supervisor labor. Adjustment to maintenance labor and
materials is done in the following manner.
Model Plant A: multiply by 1.34;
Model Plant B: add % to the number of DF booths; and
. Model Plant C: substract 1 from the number of DF and WW booths.
These factors are included to account for the change in cost as a function
of transfer efficiency (TE). TEt = TE of prime and color exterior
•coating, and TE2 = TE of texture and touch-up exterior coating.
JFor large and medium model plants, add 7.5 hp/booth to account for the air
.make-up units.
Sludge disposal is necessary for Model Plant C only. See Table C-6 for
-.the sludge disposal charge.
mBased on CARD Manual, p. 3-12.
Assumes 10 percent interest and 15-year equipment life.
8-13
-------
TABLE 8-6. ANNUALIZED COSTS FOR REGULATORY ALTERNATIVE I-25J
Cost
1.

2.
3.
4.
5.
item
Direct operating costs
Labor
Operator
Supervisor
Raw materials
Exterior coatings
EMI/RFI shielding
Maintenance
Labor
Materials
Utilities
Electricity
Natural gas
Waste disposal
Indirect operating costs
Overhead
Taxes, insurance, and
administration
Capital recovery
Total annual i zed costs
Zinc recovery value
NET ANNUALIZED COST

aA breakdown of capital and annual
Plant A
117,960
17,700
84,500
28,000
17,800
9,400
1,860
3,760
22,660
122,770
1,690
5,560
433,660
0
433,660
costs for the
Plant B
570,140
85 , 120
676,060
368,110
98,400
45,390
20,880
41,360
79,310
603,240
19 , 040
62,580
2,669,630
-5,420
2,664,210
model plants
Plant C
1,081,300
162,200
1,689,660
848,140
218,370
90,730
39,440
78,960
135,830
1 , 169 , 500
38,260
125,730
5,678,120
-10,830
5,667,290
and each
regulatory alternative is included in Reference 5.
8-14
-------
TABLE 8-7. AVERAGE COST EFFECTIVENESS OF REGULATORY ALTERNATIVES-
MODEL PLANT A
Reg. Alt.
1-25
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
Total
annuali zed
cost of
regulatory
alternative,
$/yr
433,637
450,264
441,433
613,651
428,137
444,763
435,933
359,445
608,151
376,071
367,241
433,756
Cost with
respect to
baseline,
$/yr
0
16,626
7,796
180,013
-5,500
11,126
2,296
-74,192
174,513
-57,566
-66,396
118
Total
emission
reduction,
Mg/yr (ton/yr)
0
(0)
1.17
(1.29)
2.22
(2.44)
2.48
(2.74)
3.31
(3.64)
4.47
(4.93)
5.52
(6.09)
4.84
(5.34)
5.79
(6.38)
6.01
(6.62)
7.06
(7.78)
6.34
(6.99)
Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
0
(0)
14,000
(13,000)
3,500
(3,200)
72,000
(66,000)
-1,700
(-1,500)
2,500
(2,300)
420
(380)
-15,000
(-14,000)
30,000
(27,000)
-9,600
(-8,700)
-9,400
(-8,500)
19
(17)
(continued)
8-15
-------
TABLE 8-7. (continued)
Reg. Alt.
XIII-25
XIV-25
XV-25
XVI-25
1-25/40
11-25/40
I I I- 25/40
IV-25/40
V-25/40
VI-25/40
VI 1-25/40
VIII-25/40
IX-25/40

Total
annuali zed
cost of
regulatory
alternative,
$/yr
511,785
450,382
441,552
613,769
402,815
419,441
410,611
572,664
398,943
414,973
406,142
327,498
568,196

Cost with
respect to
baseline,
$/yr
78,148
16,744
7,914
180,132
-30,822
-14,196
-23,026
139,027
-34,694
-18,665
-27,495
-106,139
134,558

8-16
Total
emission
reduction,
Mg/yr (ton/yr)
7.32
(8.07)
7.51
(8.28)
8.56
(9.44)
8.83
(9.73)
1.52
(1.68)
2.69
(2.97)
3.74
(4.12)
4.01
(4.42)
4.21
(4.64)
5.38
(5.93)
6.43
(7.08)
5.46
(6.01)
6.69
(7.38)

Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
11,000
(9,700)
2,200
(2,000)
930
(840)
20,000
(19,000)
-20,000
(-18,000)
-5,300
(-4,800)
-6,200
(-5,600)
35,000
(31,000)
-8,200
(-7,500)
-3,500
(-3,100)
-4,300
(-3,900)
-19,000
(-18,000)
20,000
(18,000)
(continued)

-------

TABLE 8-7. (continued) .
;
Reg. Alt.
X- 25/40
XI-25/40
XI 1-25/40
XIII-25/40
XIV-25/40
XV- 25/40
XVI-25/40
Total
annual i zed
cost of
regulatory
alternative,
$/yr
344,124
335,294
402,916
469,674
419,542
410,688
572,741
Cost with
respect to
baseline,
$/yr
-89,513
-98,343
-30,721
36,036
-14,095
-22,949
139,104
; Total
: emission
: reduction,
Mg/yr (ton/yr)
6.62
(7.30)
7.67
(8.46)
6.68
(7.36)
7.94
(8.75)
7.85
i (8.65)
/ 8.89
; (9.80)
9.16
( (10.10)
Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
-14,000
(-12,000)
-13,000
(-12,000)
-4,600
(-4,200)
4,500
(4,100)
-1,800
(-1,600)
-2,600
(-2,300)
15,000
(14,000)
8-17
-------
TABLE 8-8. AVERAGE COST EFFECTIVENESS OF REGULATORY ALTERNATIVES—
MODEI4 PLANT B
Total
annual i zed
cost of
regulatory
alternative,
Reg. Alt. $/yr
1-25 2,664,596
11-25 2,797,598
111-25 2,726,985
IV-25 2,764,995
V-25 2,620,592
VI-25 2,753,594
VII-25 2,682,980
VIII-25 2,511,522
IX-25 2,720,991
X-25 2,644,524
XI-25 2,573,910
XII-25 2,665,449

Cost with
respect to
baseline,
$/yr
0
133,002
62,388
100,399
-44,:004
88; 998
18,384
-153,074
56,395
-20,072
-90,686
i853

8-18
Total
emission
reduction,
Mg/yr (ton/yr)
0
(0)
9.35
(10.30)
17.74
(19.55)
19.86
(21.90)
26.44
(29.15)
35.79
(39.45)
44.18
(48.70)
38.73
(42.69)
46.31
(51.04)
48.08
(52.99)
56.47
(62.24)
50.75
(55.94)

Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
0
(0)
14,000
(13,000)
3,500
(3,200)
5,100
(4,600)
-1,700
(-1,500)
2,500
(2,300)
410
(380)
-4,000
(-3,600)
1,200
(1,100)
-420
(-380)
-1,600
(-1,500)
17
(15)
(continued)

-------
TABLE 8-8. (continued)
Reg. Alt.
XIII-25
XIV-25
XV-25
XVI-25
1-25/40
11-25/40
II 1-25/40
IV- 25/40
V-25/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40
Total
annual i zed
cost of
regulatory
alternative,
$/yr
2,642,443
2,798,451
2,727,814
2,765,848
2,488,937
2,621,939
2,551,325
2,590,038
2,453,184
2,586,186
2,515,572
2,326,862
2,554,285
Cost with
respect to
baseline,
$/yr
-22,153
133,855
63,218
101,252
-175,659
-42,657
-113,27.1
-74,558
-211,412
-78,411
-149,024
-337,734
-110,311
Total
emission
reduction,
Mg/yr (ton/yr)
58.59
(64.59)
60.10
(66.25)
68.49
(75.50)
70.61
(77.84)
12.18
(13.43)
21.53
(23.73)
29.92
(32.98)
32.05
(35.33)
33.67
(37.11)
43.02
(47.42)
51.41
(56.67)
43.65
(48.12)
53.53
(59.01)
Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
-380
(-340)
2,200
(2,000)
920
(840)
1,400
(1,300)
-14,000
(-13,000)
-2,000
(-1,800)
-3,800
(-3,400)
-2,300
(-2,100)
-6,300
(-5,700)
-1,800
(-1,700)
-2,900
(-2,600)
-7,700
(-7,000)
-2,100
(-1,900)
(continued)
8-19
-------
TABLE 8-8. (continued)

Reg. Alt.
X-25/40

XI-25/40

XII-25/40

XIII-25/40

XIV-25/40

XV- 25/40

XVI-25/40

Total
annuali zed
cost of
regulatory
alternative,
$/yr
2,459,864

2,389,250

2,489,624

2,458,485

2,622,626

2,551,989

2,590,725

Cost with
respect to
baseline,
$/yr
-204,732

-275,346

-174,972

-206,111

-41,970

-112,607

-73,871

Total
emission
reduction,
Mg/yr (ton/yr)
53.00
(58.42)
61.39
(67.67)
53.42
(58.88)
63.52
(70.01)
62.77
(69.19)
71.16
(78.44)
73.28
(80.78)
Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
-3,900
(-3,500)
-4,500
(-4,100)
-3,300
(-3,000)
-3,200
(-2,900)
-670
(-610)
-1,600
(-1,400)
-1,000
(-910)
8-20
-------
1
TABLE
\
Reg. Alt.
1-25 :
11-25
111-25
IV-25
V-25 ;
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25

8-9. AVERAGE COST
Total
annual i zed
cost of
regulatory
alternative,
$/yr
5,667,283
5,999,866
5,823,279
6,107,964
5,557,319
5,889,903
5,713,315
5,425,205
5,998,000
5,757,789
5,581,201
5,669,354

EFFECTIVENESS
MODEL PLANT
Cost with
respect to
baseline,
$/yr
0
332,584
155,996
440,681
-109,964
222,620
46,033
-242,077
330,718
90,507
-86,081
2,072

OF REGULATORY ALTERNATIVES—
C
Total
emission
reduction,
Mg/yr (ton/yr)
0
(0)
23.37
(25.77)
44.36
(48.90)
49.67
(54.75)
66.08
(72.84)
89.45
(98.60)
110.44
(121.73)
96.78
(106.69)
115.75
(127.59)
120.16
(132.45)
141. 14
(155.58)
126.83
(139.80)
Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
0
(0)
14,000
(13,000)
3,500
(3,200)
8,900
(8,000)
-1,700
(-1,500)
2,500
(2,300)
420
(380)
-2,500
(-2,300)
2,900
(2,600)
750
(680)
-610
(-550)
16
(15)
(continued)
8-21
-------
TABLE 8-9. (continued)

Reg. Alt.
XIII-25
XIV-25
XV- 25
XVI-25
1-25/50
11-25/40
111-25/40
IV-25/40
V-25/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40

Total
annual i zed
cost of
regulatory
alternative,
$/yr
5,947,279
6,001,938
5,825,326
6,110,036
5,247,521
5,580,105
5,403,517
5,683,545
5,158,176
5,490,760
5,314,172
4,982,946
5,594,200

Cost with
respect to
baseline,
$/yr
279,997
334,656
158,044
442,753
-419,761
-87,177
-263,765
16,263
-509,107
-176,523
-353,111
-684,336
-73,083
8-22

Total
emission
reduction,
Mg/yr (ton/yr)
146.46
(161.44)
150.20
(165.57)
171. 19
(188.70)
176.50
(194.55)
30.45
(33.57)
53.83
(59.33)
74.81
(82.46)
• 80.12
(88.32)
84.14
(92.75)
107.51
(118.51)
128.50
(141. 64)
109.09
(120.25)
133.81
(147.50)

Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
1,900
(1,700)
2,200
(2,000)
920
(840)
2,500
(2,300)
-14,000
(-13,000)
-1,600
(-1,500)
-3,500
(-3,200)
200
(180)
-6,100
(-5,500)
-1,600
(-1,500)
-2,700
(-2,500)
-6,300
(-5,700)
-550
(-500)
(continued)
-------
TABLE 8-9. (continued)

Reg. Alt.
X- 25/40
XI-25/40
XI 1-25/40
XIII-25/40
XIV-25/40

XV- 25/40
XVI-25/40

Total
annual ized
cost of
regulatory
alternative,
$/yr
5,315,530
5,138,943
5,249,212
5,500,363
5,581,796

5,405,184
5,685,260

Cost with
respect to
baseline,
$/yr ,
-351,752
-528,340
-418,071
-166,920
-85,487

-262,098
17,977

Total
emission
reduction,
Mg/y.r (ton/yr)
132.46
(146.01)
153.45
(169.14)
133.50
(147.15)
158.76
(175.00)
156.87
(172.92)
177.86
(196.05)
183.17
(201.91)
Average
cost effec-
tiveness of
regulatory
alternative,
$/Mg ($/ton)
-2,700
(-2,400)
'-3,400
(-3,100)
-3,100
(-2,800)
-1,100
(-950)
-550
(-490)
-1,500
(-1,300)
98
(89)
8-23
-------
8.3 REFERENCES FOR CHAPTER 8

1. R. B. Neveril, GARD, Inc. Capital and Operating Costs of Selected
Air Pollution Control Systems. U. S. Environmental Protection
Agency. Research Triangle Park, N.C. EPA Publication No. EPA-450/
5-80-002. December 1978.

2. U.S. Department of Labor. Bureau of Labor Statistics. Employment
and Earnings. January 1984. pp. 122, 130.

3. U.S. Department of Labor. Bureau of Labor Statistics. Producer
Prices and Price Indexes Data for January 1984. pp. 99, 100.

4. Peters, M. S., and Timmerhaus, K. D. Plant Design and Economics for
Chemical Engineers. New York, McGraw-Hill Book Company. 1980.
pp. 172-174.

5. Memo from Duletsky, B., J. Larson, D. Newton, and S. Smith, MRI, to
Salman, D., EPA. June 19, 1985. Revised final tabular costs.

6. Telecon. Newton, D., MRI, with Von Hor, R., Ex-Cell-0 Corp. July 22,
1983. Coatings, processes, and trends in the surface coating of
plastic parts for business machines.

7. Letter and attachments from Hall, D., Premix, Inc., to Farmer, J.,
EPA. October 4, 1983. Response to Section 114 letter on the surface
coating of plastic parts for business machines.

8. Letter and attachments from Walberg, A. C., Arvid C. Walberg and
Company, to Newton, D., MRI. March 29, 1983. Information on the
electrostatic spray coating of plastic parts.
9. Wilson, A. Methods for Attaining VOC Compliance.
Engineering. 15:34-35. April 1983.
Pollution
8-24
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9. ECONOMIC IMPACTS

9.1 PROFILE OF INDUSTRY—SURFACE COATING OF PLASTIC PARTS FOR BUSINESS
MACHINES
9.1.1 Introduction
This profile focuses on the process of surface coating plastic
parts for use in business machines. For a variety of reasons, the
surface coating of plastic parts for use in business machines is not a
truly cohesive industry but is a collection of similar processes.
Nevertheless, economic data for this activity can.be developed. This
affects the discussions presented here in two ways. First, the
format of this profile would ideally follow a particular model of
industrial organization that characterizes an industry in terms of its
basic conditions, market structure, market conduct, and market perform-
ance.1. In this profile, however, because the focus is on a process
rather than a clearly delineated industry, a clear characterization of
the economic factors may not be possible. Second, there are little
publicly available economic data on the surface coating of plastic
parts for business machines. To overcome informational shortcomings,
this profile incorporates data on the industries that employ these
particular processes. Although this approach may enrich the following
discussions, it cannot provide precise values for many meaningful
economic variables.
The purpose of this profile is to provide the reader with an
economic overview of both the surface coating processes and those
industries involved in the markets for plastic business machine parts.
It is organized into five major sections.
9.1.1.1 Description of the Surface Coating Process and Relevant
Industries. Molded plastic business machine parts are surf ace--coated to
9-1
-------
meet decorative, protective, and electromagnetic or radio interference
shielding requirements and to prevent electrostatic discharge. Surface
coating operations are performed within several industries, including
business machine manufacturers, independent plastic molders and coaters,
and "coating only" shops. Business machine manufacturers are represented
in the following standard industrial classification (SIC) codes: SIC
3573, electronic computing equipment; SIC 3574, calculating and
accounting machines; and SIC 3579, office machines. Independent
plastic molders/coaters are classified in SIC 3079, miscellaneous
plastic products. The coating only firms are represented in SIC 3471,
electroplating, plating, and polishing, and SIC 3479, coating, engraving,
and allied services. Two other industries relevant to the surface
coating process are the plastics and coatings suppliers. These
suppliers are included in SIC 2821, plastics and resins, and SIC 2851,
paints and allied products.2
As mentioned above, several factors make it difficult to analyze
the surface coating of plastic business machine parts as an industry
unto itself. First, the surface coating of plastic business machine
parts represents an intermediate step in the production of business
machines. Second, these surface coating operations are not classified
within the representative industries listed above, even at the seven-
digit SIC level. In the context of all surface coating applications,
regardless of the final product, the surface coating of plastic business
machine parts accounts for only a portion of 1 application, which
represents less than 5 percent of all applications.3 Third, it appears
that individual existing markets are so small and specialized that
publicly available data on them do not exist.
9.1.1.2 The Surface Coating Process in the Macroeconomy. Because
no specific figures are available concerning value of shipments,
value-added, employment, or new capital expenditures for these U.S.
surface coating operations, it is difficult to assess their absolute
and relative sizes. To overcome these data limitations, this section
provides ranges of probable values for different economic variables by
9-2
-------
using available data on the industries in which the surface coating
process is performed.
Based on our analysis of the market for surface coating of plastic
parts for business machines (see Table 9-12), we estimate the total
market to range from $402,000,000 to $546,000,000 (1984 $) depending
on the regulatory alternative adopted. These values represent estimated
total revenue for 1990. In terms of the entire U.S. economy, these
figures represent less than 0.02 percent of the 1984 U.S. gross national
product (GNP).4
The relative sizes of employment, value-added, and capital expendi-
tures devoted to surface coating plastic business machine parts are
not known. The size of these variables for the surface coating proc-
ess, however, is represented by a very small unknown fraction of these
variables for the industries in which surface coating is performed.
The variables for these industries are shown in Table 9-1. Note that
these industry figures are 1981 values represented as a percentage of
overall U.S. economic activity.
9.1.2 Basic Conditions
The supply and demand conditions for surface coating operations
reflect decisions made by suppliers of this process in light of pro-
duction methods, costs, and requirements; they reflect decisions made
by demanders of this process regarding the attributes provided by the
surface coating process and prevailing government regulations. The
discussions in this section are not meant to restate the material
presented in Chapter 3. Rather, these discussions provide an eco-
nomic perspective on the various factors affecting the surface coating
of plastic business machine parts.
9.1.2.1 Supply Conditions. The surface coating of plastic
business machine parts, as previously mentioned, is performed for
several general purposes. First, coatings are used to enhance the
exterior finish of the plastic parts and to help improve the resis-
tance characteristics of the parts to various forms of deterioration.
Second, coatings are used to provide electromagnetic interference/
radio frequency interference (EMI/RFI) shielding of plastic parts as
required by Federal Communications Commission (FCC) regulations.
9-3
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TABLE 9-1. RELATIVE SIZE OF INDUSTRIES RELATED TO THE SURFACE
COATING OF PLASTIC BUSINESS MACHINE PARTS (1981)
Industry
Electronic computing equipment
SIC 3573
Calculating machines
SIC 3574
Office machines, NEC3
SIC 3579
Miscellaneous plastic products
SIC 3079
Plating and polishing
SIC 3471
Coating and allied services
SIC 3479
Industry
employment,
% of total
U.S.
employment
0.32
0.02
0.04
0.46
0.06
0.04
Industry
value-
added,
% of
GNP
0.60
0.02
0.08
0.50
0.05
0.04
New capital
expenditures,
% of gross
domestic
private
investment
0.45
0.01
0.03
0.30
0.02
0.03
aNEC = Not elsewhere classified.
9-4
-------
The majority of plastic business machine parts requires surface coating
for one or both purposes stated above, although the exact percentage
is unknown. Third, coatings may be used to control electrostatic
discharge.
The primary inputs into the surface coating process are the
various coatings, which are characterized by their use in meeting one
of the three coating purposes mentioned above. Further distinctions,
common to both decorative/protective and shielding coatings, are
delineated by general characteristics in coating formulations.
For a firm that surface coats plastic parts, the amount and
sophistication of the equipment required for the coating process are
primarily a function of the type of coatings applied and the volume of
production. The basic equipment used in the application step of the
surface coating process is air-atomized spray equipment, which includes
a pump, hoses, and a spray gun. Inexpensive and readily available
from a variety of vendors, air-atomized spray equipment is used by
nearly all coaters. The basic air-atomized equipment applies low-solids
exterior coatings. With some additional equipment, such as agitators
for nickel flake coatings, metering devices, and high-pressure pumps,
air-atomized spray equipment can apply two-component higher-solids
exterior coatings and conductive metal-filled shielding coatings.
The minimal capital equipment requirements necessary for the
surface coating process are a single spray gun and booth, room to
air-dry the coated parts, and an oven. This minimal investment level
may typify the small "coating only" shops that handle small batch jobs
on a per-order basis. Capital equipment investments sufficient to
handle larger volumes of production are made by increasing application
capacities and/or by speeding up the drying times of coated parts.
Typically, larger coating facilities use more than one spray line and
more spray guns per spray line and use curing ovens to speed the
drying process. Further investments in capital equipment that enable
larger coaters to handle even larger volumes of production involve
transforming surface coating operations from a batch to a continuous
production process., which is accomplished by using conveyors to carry
parts through the entire surface coating process.
9-5
-------
To protect workers and plastic parts from high concentrations of
overspray and organic solvents associated with higher production
volumes, larger facilities apply coatings in partially enclosed spray
booths equipped with exhaust and filtration "systems. Other equipment
typically found in larger facilities, such as large "coating only"
shops and molders/coaters, includes the specialized equipment required
for zinc-arc spraying.
Because most substrate surface preparations and spraying opera-
tions are performed manually, the labor requirements per surface
coating facility generally increase with production volumes. Thus,
differences in employment levels at different coating facilities
largely depend upon the number of spray guns used and the amount of
preparation required in the surface coating process. Higher economic
efficiency levels that allow increased job specialization and capital
investments in the production process are associated with larger
production volumes. Therefore, if production volumes are large enough,
coating facilities can increase the output volume per employee by
reducing the number of different tasks performed by each worker and/or
by investing in the conveyorized equipment that changes production
from a batch to a continuous process. Also, coating facilities can
reduce their employment level per specific output volume by substituting
capital for labor, such as replacing spray gun operators with robots.
In the process of surface coating of plastic parts for business
machines, most production deci&ions are made by the machine manufacturers.
Because these manufacturers specify the coatings to be applied and the
application methods, the extent to which independent molders/coaters
and coaters not associated with business machine production facilities
can control production costs is limited. Under these circumstances,
independent firms can control costs only by varying factors of produc-
tion (capital and labor) or by improving technical production efficien-
cies at their facilities. For business machine manufacturers who
surface coat their own plastic parts and for independent firms less
restricted by manufacturers' specifications, other ways of controlling
production costs include varying the type of coatings applied and
changing the application method.
9-6
-------
9.1.2.2 Demand Conditions. The decision on the part of business
machine manufacturers to use plastic versus metal parts initiates the
demand for surface coating of plastic parts. These production decisions
reflect the manufacturers' desires to produce business machines with
certain characteristics at the lowest possible costs. The use of
plastics allows manufacturers to produce parts that are lightweight,
sturdy, and less expensive than metal parts. For example, machine
enclosures traditionally were made of metal; however, as of 1982,
roughly 40 percent of all machine enclosures were made of plastic.5
Once business machine manufacturers decide to use plastic parts,
their decisions concerning the production of those parts are important
in determining the derived demand for surface coating. Among the
chief considerations of manufacturers is the choice of molding process.
Plastic business machine parts are typically molded using structural
foam or straight injection techniques. Each, technique currently
accounts for roughly 50 percent of plastic parts produced.6 The
choice of molding technique is important to surface coating demand
because structural foam molded parts, which have a large number of
surface flaws, may require up to three times the amount of exterior
surface coating required by straight injection molded parts. Despite
its higher finishing costs, structural foam is used because it has
lower tooling costs than straight injection molding. Straight injection
molding does not become economically feasible unless lifetime production
runs of specific parts are expected to exceed 10,000 to 20,000 units.7
Required physical characteristics of particular parts are another
determinant of surface coating demand. Depending upon their particular
use in business machines, specific plastic parts require surface
coating to meet desired exterior finish, EMI/RFI shielding character-
istics, or both. Exterior finish characteristics include color,
texture, and resistance qualities. Given a particular molding proc-
ess, the extent to which decorative surface coating is applied to
enhance exterior finish characteristics depends on the degree to which
manufacturers' color and texture specifications cannot be achieved by
the molding process. The physical limitations of various plastic
9-7
-------
resins used to form the parts determine protective coating requirements.
EMI/RFI shielding is required for many machine enclosures to meet FCC
regulations. Because plastic is not a conductive material, a metallic
surface coating is required to provide parts with shielding properties.
The business machine manufacturers' determinations of which
coatings are applied also can affect the demand for surface coating.
Increasing the solids content of coatings reduces the volume of coating
sprayed. But the reduced costs associated with applying higher-solids
coatings are somewhat balanced by a larger capital investment for the
equipment required to apply this material and the higher cost per
gallon of the coating itself.
Technical improvements in the production process of plastic
business machine parts can also affect the demand for surface coating.
Examples of these improvements include molded-in color and texture for
straight injection molded parts and automatic mold changing machines.
Use of these production techniques can effectively reduce the extent
of surface coating performed or reduce production costs, although they
can require substantial capital investments.
Given that a specific amount of surface coating is required, the
amount of coatings used can be reduced by improving transfer effi-
ciencies in the surface coating process. This can be accomplished by
using different spray techniques, such as air-assisted airless, and
electrostatic spray.
Demand for plastic business machine parts and consequently demand
for the surface coating process are derived from demand for business
machines. Because data are not readily available on the growth of
plastics usage in business machines, the trends in demand for business
machines represent the best available estimates of the historic growth
in demand for the surface coating process. Table 9-2 presents the
value of industry shipments in constant 1972 dollars for computing
equipment (SIC 3573) and office machines (SIC 3579) from 1972 though
1983. During this 11-year period, the use of plastics in business
machines became widespread. Therefore, the compounded growth rates
for the two business machine categories represent conservative estimates
9-8
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TABLE 9-2. HISTORICAL COMPARISON OF VALUE OF INDUSTRY
SHIPMENTS FOR BUSINESS MACHINES WITH GNP IN
CONSTANT 1972 $109
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
GNP
1,186
1,254
1,246
1,234
1,300
1,372
1,437
1,479
1,475
1,514
1-.485
1,534
SIC 3573
Computing equipment
6.471
7.422
9.121
8.559
10.387
12.924
16.558
21.466
25.630
32.032
35.700
41. 055
SIC 3579
Office machines, N
1.296
NAb
NA
NA
NA
2.148
NA
2.366
NA
2.500
2. 380
2.428
NEC = Not elsewhere classified.
3NA = Not available.
9-9
-------
of the growth of plastic business machine parts. The sale of computing
equipment and office machines grew at a real, annually compounded rate
of 18.3 and 5.9 percent, respectively, over this period. U.S. GNP, in
constant 1972 dollars, is included in Table 9-2 for comparing the
value of shipment figures with a measure of overall business activity.
Over the 11-year period, real GNP grew at an annually compounded rate
of 2.4 percent. The 18.3- and 5.9-percent growth rates for computing
equipment and office machines, therefore, indicate comparatively
healthy industries over this period.
9.1.3 Market Structure
This section addresses the organizational characteristics of the
market(s) for the surface coating of plastic business machine parts.
Because market structure characteristics influence the conduct of
market participants, the economic aspects of market concentration,
economies of production, integration of firms, and market entry condi-
tions are examined here. For the most part, because of limited data,
discussions in this section are generalized insights into the surface
coating process.
9.1.3.1 Concentration Characteristics. As mentioned in Section
9.1.1.1, the surface coating of plastic business machine parts is
performed within several industries, including business machine manufac-
turers and independent plastic molders/coaters and coaters. The
number and distribution of these firms and their coating facilities
are not known, although it has been estimated that more than 3,000
such facilities exist.8 These coating facilities are distributed
among the following number of establishments for the SIC groupings in
which surface coating is typically performed:
SIC 3573 (computing equipment): 931
SIC 3574 (accounting machines): 64
SIC 3574 (office machines): 215
SIC 3079E (miscellaneous plastic products for electronic
machines): 391
9-10
-------
SIC 3471 (plating and polishing): , 3,447
SIC 3479 (coating and allied services): 1,648.9
It has been estimated that six companies, listed in Table 9-3,
controlled over half of the independent structural foam molding and
coating market in 1982,10 which suggests the existence of relatively
large molders/coaters capable of handling large production volumes.
However, these six companies do not necessarily control a majority of
the surface coating market, because structural foam parts represent
approximately 50 percent of plastic business machine parts produced.
A national market exists for the surface coating of plastic parts
for business machines. Because the surface coating process is part of
the production process of plastic parts, the size of the surface
coating market depends on the extent to which business machine manufac-
turers produce and coat their plastic parts. When they do not perform
the work themselves, machine manufacturers contract out to independent
molders/coaters and coaters all or part of the production of specific
parts. Typically, molders/coaters and coaters are under contract to
several machine manufacturers and, conversely, machine manufacturers
contract work out to several firms.
Surface coating facilities do not appear to be concentrated in
any particular region of the country, with the possible exception of
California. A representative list of firms that surface coat plastic
business machine parts is presented in Table 9-4. Because the surface
coating market is national and no apparent regional concentration
exists, specific geographic locations do not provide any advantages
for particular coating firms in the surface coating market.
In recent years a number of U.S. firms have moved production
overseas in an attempt to become more competitive with Japaneese and
other foreign rivals. Industry representatives cite lower labor costs
and lower corporate tax rates as the major reasons for this trend.
For example, Atari, which pays their employees at least $8 an hour
plus benefits, has shifted production to Asia where workers are paid
$8 a day.11 Barbados has been successful in attracting electronics
9-11
-------
TABLE 9-3. COMPANIES THAT CONTROLLED OVER
HALF OF THE STRUCTURAL FOAM MOLDING
AND FINISHING MARKET IN 1982

Company name/location

Amoco Plastics
St. Paul, Minnesota

Cashiers Plastic
Chandler, Arizona

Ex-Cell-0 Corporation
Athens, Tennessee

Leon Plastics
Grand Rapids, Michigan

Poly Structures, Inc.
Burlington, Massachusetts

Southeastern-Kusan, Inc.
Inman, South Carolina
9-12
-------
TABLE 9-4. REPRESENTATIVE LIST OF COMPANIES THAT PERFORM
SURFACE COATING OF PLASTIC BUSINESS
MACHINE PARTS
Company name/location
Company name/location
Cashiers Plastic
Chandler, Arizona

Component Finishing
Santa Clara, California

Como Plastics
Columbus, Indiana

Craddock Finishing
Evansville, Indiana

Eastman-Kodak
Rochester, New York

E.M.A.C.
Oakland, California

E/M Lubricants
Denver, Colorado

Finishing Technology, Inc.
Santa Clara, California
Leon Plastics
Grand Rapids, Michigan

MDS-Qantel Corp.
Hayward, California

Pitney-Bowes
Stamford, Connecticut

Poly Structures, Inc.
Burlington, Massachusetts

Premix, Inc.
North Kingsville, Ohio

Southeastern-Kusan, Inc.
Inman, South Carolina

Texas Instruments
Dallas, Texas
9-13
-------
and computer firms such as Microdata and Intel by offering full
exemption from all corporate taxes for 10 years, large cash grants for
worker training, and exemption from import duties on parts and materials.
Currently more than 70 countries including Korea, Taiwan, Singapore,
Phillippines, India, Scotland, and Mexico are competing to attract
U.S. businesses. Ireland alone has drawn almost $1 billion in ffxed-
asset investment from about 350 U.S. firms, including IBM, Apple,
Digital Equipment, Wang Labs, and General Electric.12
This trend is reflected in the import and export of computer
equipment by the United States in recent years. Import of computer
components and peripherals doubled to $8.3 billion in 1981, while
exports increased only 30 percent to $13.7 billion. The U.S. trade
deficit for office business machines increased almost 400 percent,
from approximately $500 million in 1980 to over $2,300 million in
1984.1S
It is difficult to assign any degree of product differentiation
to the surface coating process that is attributable to the different
firms that perform these operations. Because application techniques
vary only slightly and business machine manufacturers almost always
specify the molding process, type of plastic, and coatings used,
product differentiation is negligible for the surface coating process.
9.1.3.2 Integration of Coating Firms. Typically, the various
types of firms that surface coat plastic business machine parts are
vertically and/or horizontally integrated to some extent.
Firms performing surface coating operations are vertically inte-
grated if they mold the parts they coat. Business machine manufac-
turers, such as Eastman-Kodak, Pitney-Bowes, and Texas Instruments,
illustrate this vertical integration. Independent molders/coaters,
such as those listed in Table 9-3, represent the smallest extent of
vertical integration.
The extent of vertical integration among business machine manu-
facturers and molders/coaters results from the efforts of these firms
to control production costs. Integration reduces the transaction,
transportation, and production costs associated with negotiating
9-14
-------
contracts, shipping and handling parts between production stages, and
scheduling discontinuities of production. These cost savings, however,
are balanced against the increased investment required for combining
operations.
Vertical integration among business machine manufacturers provides
some advantage to the integrated firms over the lesser and nonintegrated
manufacturers. Because they can mold the parts they coat, molders/coaters
have an advantage over "coating only" firms. Surface coating is the
last stage in production of plastic parts and the molders of these
parts are more likely to maintain continual contracts with machine
manufacturers than are firms that provide only finishing services.
Horizontal integration is widespread among independent molders/
coaters and coaters. Typically, molders/coaters do not exclusively
mold and coat plastic parts for business machines. They may produce
parts for various end products such as automobiles, medical equipment,
and photographic equipment. Besides plastic business machine parts,
"coating only" firms typically coat other plastic parts and parts made
of other substrates, e.g., metal. The extent of horizontal integration
among molders/coaters and coaters reflects the applicability of these
processes in the production of parts other than for business machines.
As a result, the viability of these firms does not'depend strictly on
production of business machine parts.
9.1.3.3 Economies of Production. There is reason to believe that
some production economies of scale exist among the various independent
firms that surface coat plastic business machine parts.
Generally, larger firms can perform a wider range of surface
coating operations and handle larger production volumes. Typically,
these larger firms receive volume discounts on the coatings and equip-
ment they purchase. Further, they are more likely to be able to
afford the conveyorized equipment that allows them to surface coat
parts in a continuous process, thereby avoiding scheduling discon-
tinuities associated with batch operations. Thus, firms with large
production capabilities can surface coat plastic parts at a lower
average cost than can firms with smaller production capabilities.
9-15
-------
However, these production economies of scale for the surface
coating process are misleading if the overall production costs of
specific plastic parts are considered. When they produce large num-
bers of specific parts, large molding and finishing firms enjoy a
relative cost advantage over small firms. However, some of the cost
advantages for large firms are lost when a larger variety of parts
with smaller production runs are produced because changing molds and
coatings more frequently reduces the cost savings associated with
larger capital investments.
9.1.3.4 Entry Conditions. While the history of entry into the
supply side of the market for surface coating services is not docu-
mented, there appear to be few barriers to entry. Capital market
barriers do not appear significant because most equipment is relatively
simple and inexpensive. Further, no artificial barriers, such as
patent rights, government sanctions, or displacement barriers exist.
Ease of entry is not hampered by product differentiation because it is
negligible among firms providing surface coating services.
Vertical integration may restrict entry of new firms. A firm's
ability to receive continual contracts from machine manufacturers may
depend upon its ability to mold the plastic parts it coats. Without
the capabilities of producing or molding specific plastic parts,
companies depend upon both the machine manufacturers and the molding
companies for business. However, vertical integration is not a barrier
for aspiring market suppliers who already mold and coat plastic parts
other than for business machines.
9.1.4 Market Conduct
This section examines the independent firms that surface coat
plastic business machine parts to determine whether their conduct
approximates that of a competitive pricing, monopoly pricing, or
price-searching model. Examination of product homogeneity, industry
concentration, and barriers to entry suggests suppliers of surface
coating services are characterized by competitive pricing behavior.
The competitive pricing model suggests that suppliers of surface
coating services have little or no control over the price they charge
9-16
-------
for their services. The model characterizes suppliers as price takers,
whereby prices are determined by the overall market forces for these
services, and firms realize only a normal profit. In this model,
market structure is such that any abnormal profits realized are quickly
dissipated by increased competition among suppliers, either by increased
production levels of existing firms or by an increased number of new
suppliers.
9.1.4.1 Concentration. Concentration of suppliers largely
determines market pricing behavior. In a market characterized by many
suppliers, with no one firm producing a significant share of total
output, the behavior approaches that of perfect competition. Reinforc-
ing this notion is the extremely competitive nature of the business
machine markets, which causes manufacturers to work to reduce their
production costs continuously. Thus, if any concentration does exist,
firms are unlikely to exploit any market power in price setting due to
manufacturers' searching for relative and absolute production cost
advantages.
9.1.4.2 Product Homogeneity. The degree to which an industry's
output is perceived by demanders to be homogeneous is an important
determinant of industry pricing behavior. The more homogeneous the
product, the more difficult it is to sell it at a higher price than
that being offered by one or more competitors.
Because business machine manufacturers require specific charac-
teristics of their parts and select specific coatings for specific
parts, product homogeneity among firms providing coating services is
extensive. The surface coating process is basically the same no
matter who performs the service; as such, price differences among
suppliers are the result of cost differences and not of product dif-
ferentiation.
9.1.4.3 Barriers to Entry. The degree to which barriers to
entry effectively reduce market penetration by new firms influences
industry pricing behavior. Effective barriers to entry reduce com-
petition and allow firms to set their own prices.
9-17
-------
As previously mentioned, significant barriers to entry for new
surface coating firms do not exist. Basic coating operations do not
require substantial capital investment, which in some cases can deter
new entrants. Vertical integration could be a barrier to entry, but
only if molding/coating firms, which currently produce nonbusiness
machine parts, are prevented from entering the surface coating market
by some regulatory action.
Furthermore, because the business machine markets are so competi-
tive "with volume going up and selling prices going down," new surface
coating entrants are less apt to be hindered by traditional industry
relationships.14 Thus, the apparent lack of significant barriers
promotes the selection of the competitive pricing model.
9.1.5 Market Performance
In a profile where an industry is examined in terms of its condi-
tions, structure, conduct, and performance, performance is viewed as
the end result of the causal chain. Emphasis in this section is on
three aspects of market performance. First, small manufacturers of
plastic parts are examined concerning financial performance. Second,
recent trends-among business machine manufacturers are discussed.
Third, projections for the surface coating of plastic business machine
parts are presented.
9.1.5.1 Financial Profile of Small Manufacturers of Plastic Parts.
Ideally, this section would present the financial performance of
independent plastic molders/coaters and coaters. Unfortunately, data
limitations require a proxy approach in which the average financial
performance of plastic parts manufacturers with total assets less than
$250,000 is discussed. These small manufacturers are believed to
typify the independent firms that surface coat plastic business machine
parts. The data presented in this section are meant to provide an
understanding of the financial health of these firms and to indicate
their fiscal capabilities in financing new capital expenditures that
could result from some regulatory action.
Small manufacturers of plastic parts are examined in light of
liquidity, leverage, and profitability. Liquidity refers to a firm's
9-18
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ability to meet cash-flow obligations as they come due. Leverage
measures the degree to which a firm is financed by debt. Profit-
ability refers to the return on total investment in the firm.
Liquidity ratios are measures of a firm's ability to meet current
obligations as they come due. Two liquidity ratios are presented in
this section. One, the current ratio, is computed by dividing a
firm's current assets by its current liabilities. A firm with a
current ratio above 2.0 is considered reasonably liquid. A firm with
a current ratio below 1.0 may be unable to pay its bills on time,
which may ultimately lead to its demise. The other ratio used, the
quick ratio, is a more severe measure of liquidity. It subtracts
inventories from current assets because inventories may be less liquid
owing to physical deterioration and to the transaction costs of con-
verting them to cash. For the quick ratio, a measure of 1.0 or greater
indicates a firm's relative liquidity.
Measures of leverage indicate a relationship between debt and
assets. They show how much the firm is debt-financed versus how much
it is financed by equity. These measures help show the likelihood
that a firm will meet its long-term obligations. Further, as a firm
becomes more heavily debt-financed, it becomes increasingly difficult
for it to attract new capital. The leverage ratio used in this pro-
file is the ratio of a firm's total debt to total assets, expressed as
a percentage. While every industry has its characteristic leverage
ratio, typically a firm with a lower ratio has a lower burden of fixed
interest payments and hence can weather recessions better than can
firms with a higher ratio. However, the higher leveraged firms do
better in boom times, especially if the debts were issued at low
interest rates.
Profit ratios measure the firm's return on total investment and
help measure its ability to pay dividends to stockholders while main-
taining adequate funds to ensure growth. A ratio of 10 percent or
higher is often deemed necessary to secure these ends. Two measures
of profitability are presented here: first, the ratio of net (after
tax) profit to total assets and, second, the ratio of net profit to
shareholders' equity. Both are expressed as percentages.
9-19
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Table 9-5 shows the median liquidity, leverage, and profitability
measures for small manufacturers of plastic parts for the years 1979
and 1983. Exact comparisons made between these years' data are imper-
fect because of the different sources and assumptions made about the
median values. However, the data do allow reasonably secure con-
clusions about the general trend in the industry.
The data indicate that these manufacturers are liquid and able to
meet short-term debt obligations. These manufacturers were appreciably
more liquid in 1983 than in 1979. Table 9-5 also shows a reduction in
the median leverage level between 1979 and 1983, indicating a trend
among these manufacturers toward greater equity and less debt financing.
Finally, from the profitability ratios, the health of small
manufacturers of plastic parts appears to be good. The ratios for
1983, though down somewhat from 1979, are relatively high, which, with
the reduction in the median level of the leverage ratio, indicate an
overall sufficiency to attract new investment capital.
9.1.5.2 Recent Trends. Intense competition from domestic and
foreign producers coupled with continuous growth in demand for busi-
ness machines—especially personal and desktop terminals—has played a
large role in the development of the market for surface coating of
plastic business machine parts. The competitive forces of the elec-
tronic computing equipment industry have caused manufacturers to
search for ways to produce less expensive machines while demand has
continued to grow. Further, use of plastic parts has increased be-
cause of the need for lighter-weight, yet sturdy, materials as machines
have become smaller and more portable.
These trends are illustrated by the fact that over the 9-year
period, 1972 through 1981, real growth in the electronic computing
equipment industry (SIC 3573) has increased at an annually compounded
rate of 18.3 percent when the values of industry shipments are adjusted
for inflation.15 Comparatively, real GNP over the same period grew at
the rate of 2.7 percent per year.16 Further, the price index for SIC
3573 output showed zero growth over that period, while the GNP Implicit
Price Deflator, a measure of inflation, grew at a 7.7-percent annual
9-20
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TABLE 9-5. SELECTED FINANCIAL RATIOS FOR SMALL
MANUFACTURERS3 OF PLASTIC PARTS

1979
Median
(percent)
1981 .
Median
(percent)
Liquidity Ratios

Current0
Quick0

Leverage Ratio

Total debt/total assets

Profitability Ratios

Net profit/total assets
Net profit/net worth
1.29
55.9
18.5
42.1
1.51
1.03
15.3
13.6
Sources: Dun and Bradstreet Corporation, Business Economics
Division. Dun & Bradstreet's 1980 Key Business Ratios.
1980

Schonfeld & Associates, Inc. IRS Corporate Financial
Ratios. 1984.

Small manufacturers are defined in terms of net worth less than
$50,000 in Dun & Bradstreet's Key Business Ratios. Small
manufacturers are defined in terms of total assets less than
$250,000 in the Schonfeld Corporate Financial Ratios.

Median value of all firms earning a profit in 1983.

Current liquidity ratio = current assets/current debt.

Quick liquidity ratio = (current assets - inventories)/current
debt.
9-21
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rate.17 18 Between 1972 and 1981, demand for office machines (SIC
3579), again measured by the real value of industry shipments, grew at
a faster rate than did real GNP, a 7.7-percent annually compounded
growth rate compared to a 2.7-percent rate, respectively.19 The price
index for office machines (SIC 3579) climbed less steeply than did the
Implicit Price Deflator, rising 5.8 percent per year compared to
overall price increases of 7.7 percent per year.20
Further, the product price index for plastics and resins (SIC
2821) grew at a 13.7-percent compounded rate between 1972 and 1981.21
Despite the rapid increase in plastics and resin prices, the price
index for miscellaneous plastic products (SIC 3079) grew at a more
modest rate of 8.8 percent, compounded annually.22
9.1.5.3 Projections for Surface Coating. The outlook through
1990 for the firms that surface coat plastic business machine parts
appears quite good. The projected real growth of plastic business
machine parts requiring surface coating through 1990 is 17.0 percent,
compounded annually.23
Several important components are reflected in this projected
growth rate. " First, because demand for plastic business machine parts
is derived from demand for business machines, the growth projection
for business machines is the most important component of the surface
coating growth rate. The projected growth rate for business machines
through 1990 is 16.3 percent.24 This figure represents a weighted
average of projected real growth rates for electronic computing equip-
ment (SIC 3573) and office machines (SIC 3579). Second, an increase
of 40 to 90 percent in plastics usage in small desktop computers and
terminals is expected in the next 5 years. Consequently, an increase
in plastics usage in business machines above 16.3 percent is very
likely.25 2S Third, increases in the use of plastic parts that require
surface coating are mitigated somewhat by increases in imported business
machines (currently projected to be 35 percent growth per year),
increases in machine and parts production out of the United States,
and, finally, decreases in the percentages of plastic parts requiring
surface coatings.27
9-22
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9.2 ECONOMIC EFFECTS OF REGULATORY ALTERNATIVES
This section presents the estimated economic effects of the
regulatory alternatives for surface coating of plastic business machine
parts. The market for plastic parts coating is subdivided in this
analysis into two unrelated, competitive submarkets, one represented
by model plant A, the other by model plant B. This is done because
the costs of production differ substantially for the two plant types.
Both model plant As and Bs are expected to be continued to be built
for several reasons. Typically, the smaller plants fill a valuable
niche in the surface coating market by providing flexibility in pro-
duction. They can do many small jobs that a larger facility would not
routinely handle. These might include prototype parts or a first
production run of some parts prior to beginning large-scale production.
Consequently, even though the larger model plants have lower costs,
the smaller facilities will still be built and used, eyen at a higher
cost per square meter. Total effects are based on the sum of the
effects for each submarket. A third model plant type, C, is ignored
here because only one new plant is expected to be constructed over the
analysis period.
A New Source Performance Standard (NSPS) for surface coating
services for plastic business machine parts may impose additional
capital costs and increase annual operating costs or may result in a
decrease in those costs. Price changes for surface coating services
range from -24.4 to +41.6 percent (relative to baseline) for Market A
(composed of type A model plants) and from -12.6 to +5.0 percent for
Market B depending on the regulatory alternative. Quantities of
surface coating services supplied for both Market A and Market B range
from 23.4 to 24.6 million mVyr (251.8 to 264.8 million ftVyr) com-
pared to a baseline of 23.6 million m2/yr with no NSPS. Total costs
to society of the NSPS range from -$83.3 million to $33.24 million.
Employment changes vary with the market and changes in the quantities
and range from -0.7 to +4.2 percent. Net changes in welfare excluding
the environmental benefits range from -$33.24 million to $83.3 million.
9-23
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9.2.1 Methodology and Data Inputs
The methodology employed to estimate the potential economic
effects of the regulatory alternatives has two separate components. A
model based on discounted cash flow analysis is used to compute the
unit costs of plastic parts coating. Then, given these costs and
other market parameters, a competitive model of the market for plastic
parts coating is used to project the economic effects of the regulatory
alternatives. These models are described below.
9.2.1.1 Unit Cost Estimation Model. The unit costs of NSPS for
surface coating of plastic business machine parts are estimated using
a discounted cash flow (DCF) analysis. Under this approach, the
expected future annual costs of an investment in a surface coating
facility are discounted and then annualized at an appropriate interest
rate to determine the minimum price at which the investment would be
profitable. This is when the net present value (NPV) of the investment
is zero. This section describes the DCF methodology used.
An investment is expected to generate a series of cash inflows
and outflows during its lifetime. The net cash flow in the first year
(year zero) is negative because the cash outflows for the initial
investment are not offset by any cash inflows. After production
begins, the investment generates a stream of cash inflows of revenues
from the sale of its output and depreciation of the capital investment,
and cash outflows of operating expenses. Beginning with year one and
continuing throughout the lifetime of the project, annual cash flows
are expected to be positive, but need not be. Although cash flows may
occur at any time, we assume they will take place at the end of the
year. We also assume that the only investment in the project takes
place at the end of year zero and is followed by a series of net cash
inflows. These assumptions guarantee a unique rate of return for each
project.
The cash outflow in year zero may be expressed
YQ = (FCC + WC)
(9-1)
9-24
-------
where

Y = Cash flow in year zero

FCC = Capital investment

WC = Working capital (E/6)

E = Total operating costs.

The project generates its first revenues at the end of its first
year of production (year one). The net cash flows in this and subse-
quent years can be expressed
= (Rt - Et)(l-T)
DTX., t = 1, ... 15 (9-2)
d = 1,2,3,4,5
where
Y. = Net cash flows in year t

R. = Total revenues in year t

Et = Total operating costs in year t

T = Corporate income tax rate

DTXd = Tax savings from depreciation.

The first term, (R. - E.)(1-T), represents the net after-tax
I* U
inflows of the facility generated by the sales of the output. Total

revenues in year t can be expressed

Rt = (P-Q)t (9-3)

where

P = Price per unit of output

Q = Quantity of output sold during the year.

Total operating costs in year t can be expressed

Et = C(V-Q) + F]t (9-4)

where

V = Variable cost per unit of production

F = Fixed annual cost of operating the facility.
9-25
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Variable costs include expenditures on material inputs, labor, and
energy. Fixed costs include such expenses as site rent (explicit or
implicit), insurance, and administrative overhead.
Only net revenues are subject to the corporate income tax (T).
Consequently, annual total operating cost is deducted from total
revenue to yield the taxable net revenue. The firm's after-tax net
revenue in year t is thus the first term in Equation (9-2).
Current Federal tax law allows accelerated depreciation of assets
under the Accelerated Cost Recovery System (ACRS) formula. The depre-
• u-i u • T * P/T Investment Tax Credit^ v c. . /.,_-• + ,n r^-n
ciable base is equal to [(1 s ' Fixed Capital CostJ
or 95 percent of the Fixed Capital Cost (based on the Tax Equity and
Fiscal Responsibility Act of 1982). For depreciation purposes the
lifetime of the capital is 5 years, which is significantly shorter
than the projected actual lifetime of the investment. Table 9-6 shows
the depreciation schedule for a 5-year property under the ACRS. Along
with the investment tax credit, this accelerated depreciation schedule
significantly lowers the effective cost of capital to a firm.
The tax savings from depreciation expenses are defined by the
expression
DTK, = [FCC - (
TCRED • FCC
)] • DEP.
T, t = 1,2,3,4,5 (9-5)
where
DTK. = Tax savings from depreciation
DEP. = Depreciation percentage for years 1 to 5 as shown in Table 9-6.
U
The net cash flows represented by Equation (9-2) occur at the end
of the first through the Nth years, where N is the life of the project.
The investment tax credit, equal to 10 percent of the fixed capital
cost, is assumed to occur in year 1. An additional cash inflow occurs
at the end of the Nth year when the working capital, WC in Equation (9-1),
is recovered at the end of the project. The salvage value of the
plant is assumed to be zero.
The investment project is thus represented as a cash outflow in
the first year followed by N cash inflows and outflows in successive
9-26
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TABLE 9-6. DEPRECIATION DEDUCTIONS UNDER THE
ACCELERATED COST RECOVERY SYSTEM
Year
Percentage of depreciable base
1

5
15

21
Source: Tax Guide for Small Business. Department of the
Treasury. Internal Revenue Service. 1983.
9-27
-------
years. Cash flows that occur over a future period must be discounted
by an appropriate interest rate to reflect the fact that a sum of
money received at some future date is worth less than an equal sum
received today. The discounted value of this sum received in the
future is called its present value. The discount factor is a function
of both time and the interest rate and can be expressed as
DFt = (1 + r)-t (9-6)
where
DF+ = The discount factor for year t
t
r = Interest rate.
An understanding of the discount factor and the selection of an
appropriate rate of interest in practice is important. The interest
rate r in Equation (9-6) can be viewed as the cost to the firm of
acquiring funds for the project. The firm can acquire funds in essen-
tially any combination of three ways. It can issue bonds, sell stock,
or utilize currently held liquid assets. There is a cost associated
with each method. Interest must be paid on bonds and dividends on
stock, and there is an opportunity cost associated with utilizing
internal funds. In the absence of specific information on how a proj-
ect would be financed, a weighted average cost of capital can be used.
The discounted cash flow model is used to determine the minimum
average total cost (ATC) of production. This is where the net present
value of the investment is zero. This value for ATC is also the
minimum price for surface coating services needed to justify investment
in new facilities. The ATC values for all regulatory alternatives are
calculated as follows:
15
NPV = I
t=l
DFt) -
= 0
(9-7)
Substituting Equation (9-2) and rearranging,
9-28
-------
15 5
NPV = I (R*-Et) (1-TJ DF. + I (DTXt) (DF. )
t=1 t t t t=1 t t

+ (0.1XFCC) . WC _ Y
/"i « .-\ V-i . ._\ i s ™" i - •
(9-8)
(1+r) D+r)
If revenues and expenses are the same over all periods and depreciation
occurs in the first 5 years only, then
15 5
(R-E) (1-T) • I DF. + I (DTX.) (DF.)
t=l L t=l L r
+ (0.1KFCC) WC _ Y
Y '
(9-9)
The sum of the discount factors as t ranges from 1 to 15 can be written
~N
15 1 -
F = I DF. = ' •*• Y
t=l
where

F = Sum of the discount factors from 1 to 15.

Substituting Equations (9-10) and (9-1) into (9-9) yields
(9-10)
(DTX,) (DF,)
. (9-11)
Substituting Equations (9-3) and (9-1) into Equation (9-11) and rearrang-
ing yields
(FCC+WC)- I (DTXt)(DFt) - ^

.OVF= £1 (1-T)(F)
(P-Q)-E
(9-12)
Further rearranging provides

5
(FCC+WC) - I (DTX.)(DF+) -
t=l L l
(9-13)

(1-TXFXQ)
9-29
-------
where
P = ATC
First term = Capital cost per unit output including allowances
for the investment tax credit and depreciation.
Second term = Operating cost per unit.
Chapter 6 identifies and discusses 32 regulatory alternatives.
As shown in Table 9-7, each model plant has a unique set of fixed
capital and annual operating costs based on its capacity. Consequently,
the economic effects of the proposed NSPS will depend on which types
of facilities are actually constructed. The costs are taken directly
from tables in Chapter 8 except that annual operating cost excludes
any capital recovery factor. Capital costs in Table 9-7 are used in
the FCC term of Equation (9-1) and annual operating costs are employed
in the E term in Equation (9-2).
Table 9-8 lists the parameter values used in the model to determine
ATC. A value of working capital equal to 2 months of the annual
operating costs (E/6) is assumed. Because surface coating is a labor-
and materials-intensive process, the primary component of working
capital is those funds tied up in raw materials inventory, payroll,
utilities, and accounts receivable. This value is representative of
the required working capital.
The investment tax credit is 10 percent; we assume the entire
fixed capital cost is eligible for that credit. The Federal and
average State marginal corporate tax rates are assumed to be 46 percent
and 6 percent, respectively. Because State taxes are deductible from
taxable income for Federal tax purposes, the overall effective tax
rate is 49 percent. The project life is assumed to be 15 years. A
discount rate of 10 percent is employed, based on Office of Management
and Budget (OMB) guidelines.
In 1990, the total square feet of plastic parts surface coated is
projected to be 23.6 x 106 m2 (254 x 106 ft2) if there were no NSPS.
Of this amount, 15.4 x 106 m2 (166 x 10s ft2) will be produced from
existing facilities and 8.2 x 106 m2 (88 x 106 ft2) from new facilities
9-30
-------
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9-31
-------
r
TABLE 9-8. MODEL PARAMETER VALUES
Parameter
Value used
Working capital (WC)
Federal investment tax credit
Federal corporate tax rate (FT)
State corporate tax rate (ST)
Project life (N)
Discount rate (r)
E/6
0.1 x FCC
46%
6%
15 years
10%
9-32
-------
subject to the NSPS regulation. Of the total, approximately 33 percent
is projected to be produced by model plant A facilities and 67 percent
by model plant B facilities. Only one model plant C is expected to be
built oy 1990. Its output would represent only 2 percent of the total
output in 1990, and is excluded from this analysis.
Because the ATC is significantly different for each model plant,
we have treated the markets served by each group of model plants as if
they were different. Because only one model plant C-sized facility is
projected, the analysis assumes 33 percent of output is provided by
type A model plants, 67 percent by type B model plants, and none by
type C model plants. Effects are determined for each market and then
aggregated for the total industry.
Table 9-9 shows the estimated ATC values for each regulatory
alternative in each submarket. The baseline values are also shown.
9.2.1.2 Market Model. The analytic framework for the market
model that is applied in this analysis depends heavily upon the work
of W.E.G. Salter.28 The framework is based on standard microeconomic
theory, employs a comparative statics approach, and assumes certainty
in relevant markets. Price and quantity are determined by market
forces, not by individual market participants.
Overview
The approach recognizes that there are two distinctly different
types of production decisions: operating decisions and investment
decisions.
Operating decisions involve simply whether or not a firm with
plant and equipment already in place purchases inputs to produce
output. These are sometimes called short-run decisions because the
decision period is sufficiently short that certain inputs, namely
plant and equipment, are fixed. A profit-maximizing firm will operate
existing capital if the market price for its output exceeds its unit
variable costs of production. If the market price even marginally
exceeds average operating cost, the producing plant will cover not
only the cost of its variable inputs but will cover part of its capital
cost as well. A profit-maximizing firm will not pass up an opportunity
9-33
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TABLE 9-9. UNIT COST OF PRODUCTION FOR MODEL
PLANTS A AND B, 1990
($/m2)

Regulatory
Alternative
1-25 (BASELINE)
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
XIII-25
XIV-25
XV-25
XVI-25
1-25/40
11-25/40
111-25/40
IV-25/40
V-25/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40
X-25/40
XI-25/40
XII-25/40
XIII-25/40
XIV-25/40
XV-25/40
XVI-25/40

Model Plant A
30.69
31.86
31.24
43.44
30.30
31.47
30.85
25.44
43.05
26.62
25.99
30.69
36.24
31.87
31.24
43.45
28.51
29.68
29.06
40.58
28.24
29.37
28.74
23.19
40.23
24.36
23.74
28.52
33.27
29.69
29.06
40.55

Model Plant B
14.64
15.37
14.98
15.19
14.40
15.13
14.74
13.80
14.95
14.53
14.14
14.64
14.52
15.37
14.99
15.20
13.68
14.41
14.02
14.23
13.48
14.21
13.82
12.79
14.04
13.52
13.13
13.68
13.51
14.41
14.02
14.24

Note: 1 sq aieter = 10.764 sq feet.
9-34
-------
to recover even part of the initial investment it made in the plant
and durable equipment and will continue to operate such a plant in the
short run.
Investment decisions differ from operating decisions in that they
involve whether or not the firm should put in place new plant and/or
equipment. The investment decision is sometimes called a long-run
decision since the time frame is sufficiently long that all inputs,
including capital, are variable. A firm will not invest in new capital
unless current and expected future market price is sufficient to cover
both the cost of operating the new capital (variable costs) and the
cost of purchasing and owning the capital, including a normal rate of
return. Put differently, a firm will not invest unless market price
is expected to equal or exceed average total cost.
The hypothesized supply schedule from a single existing plant is
depicted in panel (a) of Figure 9-1. Given the capital in place, the
plant owner is willing to supply output Q* as long as market price
equals or exceeds the plant's average operating cost (AOC). If market
price is below AOC, the owner is unwilling to produce even a fraction
of Q* because a per-unit loss would be incurred. If market price
should substantially exceed AOC, the owner would be wi11ing to produce
output beyond Q* but is unable to do so given plant capacity.
The hypothesized supply schedule from an as yet unconstructed
plant is depicted in panel (b) of Figure 9-1. Because the plant and
equipment are not yet in place, all inputs are variable. The scale
(capacity) of the plant itself is variable. Thus, the supply schedule
does not turn up at any output rate. The assumption of a perfectly
elastic plant supply curve is probably realistic. It is unlikely that
input factor prices would be bid-up by the demands of a single plant.
Supply will not be forthcoming from the new plant, that is, it
will not be built, unless market price exceeds the average total cost
of production. The plant will be constructed only if the anticipated
market price is sufficiently above average operating cost to recover
the capital investment and provide a normal return on the capital.
9-35
-------
r
S/Q
AOC-
Q/time
(a) existing supplier
S/Q
ATC
• Q/time
(b) new supplier
Figure 9-1. Supply schedules for constructed and unconstructed plants.
9-36
-------
With an understanding of plant-level supply, focus is now directed
toward market-level considerations. The willingness of existing
plants with different average operating costs to produce at a different
minimum market price results in the upward slope of the supply schedule.
This is illustrated in panel (a) of Figure 9-2. The newest plant,
which is of vintage n-1, has the lowest average operating cost. Thus,
it is willing to supply output as long as price at least equals Px.
Plants constructed in successively earlier periods have increasingly
higher average operating costs and are willing to produce only at
higher prices. The oldest plant, produced in period n-5, has the
highest average operating cost and is the oldest existing plant that
is willing to produce at prevailing price P*; it is thus said to be a
marginal plant. In panel (b) of Figure 9-2, the conventional equilib-
rium determination of market price and quantity is depicted. Market
demand (D) is assumed to be downward sloping. The stepped supply
curve for existing suppliers is smoothed and is S.
During any period of time, the market output of a good is the sum
of the quantities produced by individual plants. As discussed above,
once a plant is in place, it will usually produce as long as market
price is equal to or greater than its average operating cost. Failure
to do so would involve passing up an opportunity to earn some return
on existing fixed capital.
Now that it is understood why the supply schedule is upward
sloping to Q*, it is time to investigate the slope of the supply
schedule beyond Q*. This is a question of long-run supply because
output in excess of Q* can be produced only after a new plant has been
constructed. The question then becomes, what is the market price at
which a new plant will be constructed?
All costs of an unconstructed plant are variable costs. The
prospective builder will invest in the new plant only if the antici-
pated market price is sufficiently high to cover average total cost,
which is average operating cost plus average capital cost, including a
normal return on the capital.
9-37
-------
S/Q
n-1 n-2 n-3 n-4 n-5
• Q/time
(a)
S/Q
Q/time
Figure 9-2. Market equilibrium.
9-38
-------
In Figure 9-3, plant n represents the as yet unconstructed plant.
In the figure, oa is the average operating cost of the new plant. The
cost component aT is the average capital cost of the new plant. This
cost component represents the return per unit output in excess of
operating cost required to repay the principal of the original capital
investment and earn a normal rate of return on that investment. The
firm's desire to recover the investment principal and earn a normal
return holds for both existing facilities and facilities under con-
sideration. In the latter case though, even these costs are variable,
indeed they are avoidable. The firm has the alternative of not build-
ing at all; i.e., of investing in another project. Thus, the new
plant will be built only if market price equals or exceeds average
total cost oT. Once built, it will supply output Q1 - Q* as long as
market price covers average operating cost; its capital costs become
sunk. Thus, the long-run supply schedule, at least from Q* to Q', is
elastic where price equals average total cost of the best technology
plant.
The validity of assuming perfectly elastic long-run market supply
is unknown. For relatively small increases in market output resulting
from the construction of, say, only a few new facilities, the assump-
tion is probably reasonable. If, however, the number of newly con-
structed facilities increased market demand for factors.of production
significantly, it is possible that factor prices would be bid up and
that long-run supply would be upward-si oping.
Market Equilibrium Without an NSPS
Figure 9-4 shows the long-run equilibrium conditions for a plastic
parts surface coating market. Demand is assumed to shift over the
1985-90 period as shown. The 1990 market-clearing price and quantity
are PI and Q2, respectively. Output Ql represents the component of
1990 output, Q2, that is produced by suppliers that were in existence
in 1985. For the purpose of this analysis, it is assumed that existing
suppliers are operating at full capacity and cannot expand output
beyond Ql. Additional output in excess of Ql can be produced only if a
new plant has been constructed. The price PI represents the market
9-39
-------
Figure 9-3. Long-run supply.
9-40
-------
$/m'
SUPPLY (1985)
SUPPLY NEV

DEMAHD<1990)

DEM AND (1985)
Figure 9-4. Market equilibrium without NSPS.
9-41
-------
price at which new plants will be put in production. Output Q2-Q1
represents the amount.of output supplied by facilities added over the
1985-90 period.
In Figure 9-5, the total costs of production are represented by
area A + B. Area A is the annual cost of production from suppliers in
existence in 1985 that are still coating plastic parts in 1990.
Consumer surplus is represented by area C, producer surplus by D.
Equilibrium price and quantity values for each plastic parts coating
submarket are shown in Table 9-10.
Market Effects of an NSPS
Typically, an NSPS will raise the ATC for new suppliers. However,
in some cases it may lower costs. Both cases are discussed below. In
all there are four generic possibilities.
Case 1
In Figure 9-6 the NSPS has created cost increases that result in
an upward shift in supply for new suppliers as shown. Price increases
to P2, quantity demanded falls to Q3. As discussed above, existing
suppliers are willing to increase output beyond Ql but are unable to
do so given their plant capacity. Their output is fixed at Ql. Output
from new suppliers falls from Q2 - Ql to Q3 - Ql. New suppliers'
costs fall by area F due to the reduction in their output. On the
quantity still produced (Q3 - Ql), compliance costs are represented by
area H. Finally, consumer benefits fall by area F + I with less
output purchased. In summary, the costs of the NSPS are
Existing suppliers = 0
New suppliers = H - F
Consumers = F + I
Net costs = H-F + F+I
= H + I.
Area H is the compliance costs for the new suppliers. Area I is
the net cost of the forfeited output (Q2 - Q3).
Producer surplus increases by area G; consumer surplus falls by
G + H + I. Thus, the costs net of transfers are: G + H + I-Gor
H + I.

9-42
-------
SUPPLY (1935)

SUPPLY NEV

DEMAHIK1990)
Ql Q2

Figure 9-5. Costs and benefits without NSPS.
m2/yr
9-43
-------
TABLE 9-10. EQUILIBRIUM PRICE AND QUANTITY VALUES
WITHOUT AN NSPS, 1990

Submarket
A
B

Price
$/«2
30.69
14.64
Quantity 10
Existing
suppliers Ql
5.20
10.22
62.
m /yr
New
suppliers Q2
2.79
5.39
Note: 1 sq »eter = 10.764 sq feet,
9-44
-------
$/m<
P2
PI
SUPPLY (1985)
Q3
Q2
1 SUPPLY NEW/REG
SUPPLY MEV

DEUANDU990)
m2/yr
Figure 9-6. Market effects of NSPS: Case 1.
9-45
-------
Case 2
In some cases, NSPS may raise the costs for new suppliers such
that no new facilities are put in place for the analysis period. This
outcome is presented here as Case 2.
As shown by Figure 9-7, the cost for new suppliers increases
above the market price P3. Quantity demanded falls from Q2 to Ql.
Output from new suppliers falls to zero (Q2 - Ql). Existing suppliers
continue to produce at output rate Ql. Their costs fall by J. Consumer
benefits fall by J + L. Summarizing the effect of the NSPS on costs
Existing suppliers = 0
New suppliers = -J
Consumers = J + L
Net costs = J + L - J
= L.
Producer surplus increases by area K; consumer surplus falls by
K + L. Thus, the costs of the NSPS, net of transfers, are: K + L - K
w I
™" L •
Case 3
Several of the regulatory alternatives have lower ATC than the
baseline. It is generally assumed that individual firms select least-
cost production techniques when adding new capacity. However, aversion
to change and the risks associated with that change, especially the
use of a new or emerging production technology, affects a firm's
decision. Firms may have information that a different technology
provides surface coating services at a lower unit cost than current
installed technologies; but, the uncertainty of switching to a new
technology restricts their choosing this lower-cost alternative in the
immediate future. In the long-run, as new technologies become more
tested and are used by more firms, the perceived risk of using a new
technology is lowered and the firm will select the least-cost alterna-
tive.
In Figure 9-8 the effects of an NSPS that lowers the cost for new
facilities is shown. Output increases by Q4 - Q2 to Q4. Output from
9-46
-------
SUPPLY <1985)
SUPPLY NEVV/BEG

SUPPLY MEV

DEMAMII<1990)
m2/yr
Figure 9-7. Market effects of NSPS;. Case 2.
9-47
-------
$/m2
PI

P4
M
SUPPLY (1985)

,-.v.s-v.v-s>v\s\v-v-s\v-v
f*f*f:f:f:fi^:f:f-f*^:ff'
SUPPLY HEV

SUPPLY MEVV/BEG

' DEMAHIX1990)
Q5
Q2
Q4
m 2/yr
Figure 9-8. Market effects of NSPS: Case 3.
9-48
-------
existing suppliers falls by Ql - Q5 to Q5. Output from new suppliers
increases by Ql - Q5 + Q4 - Q2 to Q4 - Q5.
Costs for existing suppliers fall by area M + Q. For new suppliers
costs increase by M - R + S. Consumer benefits increase by Q + S. In
summary, costs change by
Existing suppliers = -M - Q
New suppliers = M - R + S
Consumers = -0 - S
Net=-M-Q+M-R+S-0-S
= -Q - R - 0.
The loss in producer surplus is P. The gain in consumer surplus
is -P - Q - R - S. The cost net of transfers is -Q - R - S.
Case 4
In some cases the new production methods may be so efficient that
all existing suppliers must retire their existing plant. This is the
situation illustrated here.
In Figure 9-9 supply shifts downward as indicated below the
lowest-cost current supplier. The NSPS results in an output increase
of Q6 - Q2 to Q6. Production from existing suppliers falls by Ql to
zero. Output from new suppliers increases by Ql + Q6 - Q2 to Q6.
Existing suppliers costs fall by T + X. Those for new suppliers
increase by T + V. Consumer benefits increase by V + Z. In summary,
the cost changes are
Existing suppliers = -T - X
New suppliers = T - Y + V
Consumers = -V - Z
Net cost =-T-X+T-Y+V-V-Z
= -X - Y - Z.
Looked at from the perspective of income streams, producer surplus
falls by W; consumer surplus increases by W + X + Y + Z. The income
effects, net of transfers, are: -W+W+X+Y+Z=X+Y+Z.
9-49
-------
$/m
SUPPLY (1985)
SUPPLY HEV

DEMAND<1990)
SUPPLY
HEV
V/KEG
Figure 9-9. Market effects of NSPS: Case 4.
9-50
-------
Table 9-11 shows which case applies for Market A and for Market B by
type of regulatory alternative.
To project the market adjustments requires estimates of the
demand and supply elasticities. For this analysis, a relatively
inelastic demand of -0.25 is assumed. The demand for surface coating
of plastic parts for business machines is derived from the demand for
the business machines. Because the actual cost of surface coating
plastic parts is not a significant cost of production for business
machine producers, we assumed that demand for surface coating would be
inelastic. The effect of changes in demand elasticities on the results
of the analysis are reviewed in the sensitivity analysis in Section 9.2.4.
A separate supply function for existing suppliers is estimated
for each market and the point elasticity of supply computed. The
supply function is assumed to be linear between the baseline cost and
the average variable cost for a new facility. Thus, the most efficient
(least-cost) existing supplier is assumed to be a plastic parts coater
recently put in place. The marginal existing supplier is assumed to
have average variable cost equal to the baseline cost estimate. The
estimated supply elasticities are
Market A: 22.23
Market B: 17.87 .
9.2.2 Economic Effects of Regulatory Alternatives
The economic effects discussed in this section include both direct
and indirect components. Direct effects occur due to the impact of
the NSPS on new surface coating facilities, e.g., an increase or
decrease in the capital cost of a new facility. Indirect effects
occur from the impact on existing facilities that are not directly
affected by the NSPS. For example, if the NSPS requires technology
that results in production cost savings, new plants will produce at
lower costs than existing facilities. If these differences are signif-
icant enough, existing facilities may have to modify their production
processes to remain competitive with new facilities.
Without the NSPS, many firms would still switch to the new technol-
ogy required under the NSPS because of its cost-effectiveness. This
9-51
-------
TABLE 9-11. PRICE CHANGE ANALYSIS BY
REGULATORY ALTERNATIVE
Regulatory
Alternative
Market A

Type of
price change
Market B

Type of
price change
1-25
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
XIII-25
XIV-25
XV-25
XVI-25
1-25/40
11-25/40
111-25/40
IV-25/40
V- 25/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40
X-25/40
XI- 25/40
XII-25/40
XIII-25/40
XIV-25/40
XV-25/40
XVI-25/40
Case 1: Pg < PN < P£
Case 2: PC < PN
Case 3: PAVC < PN < PB
Case 4: P.. < P..,., < PD
Baseline
1
1
1
3
1
1
4
1
4
4
1
1
1
1
1
4
3
4
1
4
3
4
4
1
4
4
4
1
3
4
1

Baseline
1
1
•1
3
1
1
4
1
3
3
1
3
1
1
1
4
3
3
3
4
3
3
4
3
4
4
4
4
3
3
3

where:
PB = Baseline price, no NSPS.

PN = Price after NSPS.

PC = Equilibrium price if NSPS increases costs for new
suppliers and demand shift to 1990 quantities
($56.62/m2 for Market A; $26.S6/m2 for Market B).
rAVC
= Average variable cost for the newest existing
plant ($29.30/m2 for Market A and $13.82/m2 for
Market B).
9-52
-------
analysis assumes that firms would not have switched to the VOC-reducing
technologies in 1990. Consequently, it represents the maximum effects
that may occur as a result of the NSPS.
9.2.2.1 Price and Quantity Effects. The major economic effects
of the regulatory alternatives are presented in this section. The
year of analysis is 1990, 5 years from the anticipated proposal of an
NSPS for surface coating of plastic business machine parts. These
effects are short-run effects only in the sense that in 1990 some
currently existing facilities will still be operating.
Changes in baseline values for the price and quantity for plastics
parts surface coating services are projected for each regulatory
alternative using a comparative statics approach. This approach
assumes certainty in relevant markets and that market prices and
quantities are determined by market forces and not by individual
agents.
As noted earlier, the market for surface coating services is
segmented into two equal parts: one served by type A model plants and
one served by type B model plants. This segmentation assumes each
market segment.is autonomous from the other; consequently, type A
model plants compete only with other type A model plants. Dividing
the market in this way provides a more accurate model of the actual
surface coating market than does a market model characterized by a
representative firm of only one size. The price and quantity effects
are calculated separately for each market segment.
Table 9-12 shows the projected price and quantity effects for
each regulatory alternative for each market segment and the total
industry. The total industry-wide quantity effects are determined by
adding the effects of the two markets—A and B.
Three of the four cases described in the methodology above
are represented in Table 9-12. For regulatory alternatives that
increase costs for new sources, the price effect shown is the minimum
equilibrium price for existing suppliers (P3 in Figure 9-7) or the
unit cost of the NSPS. The demand for surface coating is projected to
fall. Output from existing suppliers will remain at current levels
9-53
-------
i!
2Jg55;§;S2?SSSS55;§K£gS§SSS5SggE;5g

4 ! 3S!35S5S!SSSSS3S3SS!3Si3SS2SS3SSE»»S":
e''
o i 10 mototen K

,oTooo.
o u o«ni»no«ene«M*»weniotoMi
• l
* «•-• i o
-------
due to the capacity of the existing plants. Additional output required

to satisfy the demand.for surface coating will be provided by new

suppliers.

For regulatory alternatives that reduce costs, the price of

surface coating of plastic parts is projected to fall. Output from

existing facilities will decline while output from the more efficient

new facilities will increase. For regulatory alternatives where the

price falls below the average variable cost, when average variable

cost is defined as annual operating cost divided by the amount of

output from a model plant, output from existing suppliers will fall to

zero. All production will come from more efficient new suppliers.

9.2.2.2 Costs. Regulatory alternative costs are projected for

three market participants—existing suppliers, new suppliers, and

consumers. These costs are summarized by market in Tables 9-13, 9-14,

and 9-15 for the following categories:

Existing Suppliers. They do not incur direct compliance
costs because the NSPS is only applicable to new facil-
ities. However, they may incur indirect costs as a
result of adjusting to the market for surface coating
services which is changed by the imposition of the NSPS.
Production costs for existing suppliers will change
depending on how the NSPS impacts industry price struc-
ture. If the NSPS increases prices, existing plants will
produce more surface coating services at the higher
price; this results in increased production costs. If
the NSPS results in decreased prices, production costs
for existing facilities may decline as less services are
provided by existing plants and more by the lower cost
new plants.

New Suppliers. Like existing suppliers, new suppliers
are similarly affected by increased or decreased prices
resulting from the NSPS. In addition, new suppliers
incur a compliance cost that existing suppliers do not.
Depending on the direction of the price change, the
compliance costs may be positive or negative. Negative
compliance costs occur when the supplier, as a result of
the NSPS, enjoys a decline in real resource costs of
producing surface coating services.

Consumers. Depending on the direction of the quantity
change, consumers either gain or lose with the NSPS. For
example, an NSPS that lowers prices induces consumers to
9-55
-------
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9-58
-------
purchase some plastic parts coating services, thereby
increasing their welfare. The dollar value of the increase
in welfare is treated as a negative cost in this analysis.
As shown in Table 9-15, 17 of the regulatory alternatives reduce
the cost of surface coating plastic parts while 15 of the alternatives
increase cost. The net gains or losses to the market participants for
each regulatory alternative are presented in Section 9.2.2.7.
9.2.2.3 Employment Effects. Changes in the production rate of
surface coating services are expected to cause changes in the rates of
resource utilization. Effects on the levels of employment in affected
industries are particularly important. Projecting these effects is
difficult because surface coating is a process and employment data for
only the surface coating process are not available.
The employment effects for each market and regulatory alternative
are estimated by assuming that employment effects will be directly
proportional to quantity effects; i.e., a 10-percent increase in the
quantity of plastic parts coated would cause a 10-percent increase in
employment in the surface coating industry and vice versa. Table 9-16
presents projected changes in employment for each regulatory alternative.
Some of the regulatory alternatives reduce labor requirements.
Where plastic parts coating is part of a vertically integrated process
within a firm, it seems likely that many of the displaced workers
would find other employment within the firm. The regulatory alterna-
tives that lower costs and hence price would encourage additional
plant construction and hence additional employment.
9.2.2.4. Foreign Trade Effects. The proposed regulation could
have a significant effect on the industry. If it lowers the cost for
producers, U.S. manufacturers may remain competitive in the market
without having to purchase foreign components or moving production
overseas. However, if the proposed regulation results in a significant
increase in the cost for supplies, domestic firms may find it necessary
to use cheaper foreign components or move their production overseas to
remain competitive. The extent to which this occurs will depend on
the relationship between the costs for surface coating services and
the total cost of manufacturing plastic parts for business machines.
9-59
-------
TABLE 9-16.
EMPLOYMENT EFFECTS

Change in
Market A
0.00
-0.96
-0.45
-10.39
0.32
-0.64
-0.13
4.27
-10.08
3.31
3.82
-0.01
-4.53
-0.96
-0.46
-10.40
1.77
0.82
1.32
-8.06
1.99
1.07
1.58
6.11
-7.78
5.15
5.66
1.77
-2.10
0.81
1.32
-8.04

eaployaent ,
Market B
0.00
-1.25
-0.58
-0.94
0.41
-0.83
-0.17
1.43
-0.53
0.19
0.85
-0.01
0.20
-1.25
-0.59
-0.95
1.64
0.40
1.06
0.69
1.98
0..73
1.40
3.16
1.03
1.92
2.58
1.64
1.93
0.39
1.05
0.69

percent
Total
0.00
-0.68
-0.54
-0.68
0.38
-0.68
-0.16
2.39
-0.55
1.25
1.85
-0.01
-0.07
-0.68
-0.55
-0.68
1.69
0.54
1.15
0.26
1.99
0.85
1.46
4.16
0.48
3.01
3.62
1.68
1.07
0.53
1.14
0.25

9-60
-------
We do not anticipate that the proposed regulation will cause signif-
icant changes in the existing trends towards more overseas production
of business machines.
9.2.2.5" Plant Closures. Any changes in price will usually
result in changes in sales volume. As noted earlier, if an NSPS
causes the price to go above the equilibrium price (see Case 2
pp. 9-46 and 9-47) there will be no new facilities installed. Con-
versely, a drop in price will generate pressure to build new facil-
ities to satisfy the increased demand. However, installation of new,
low-cost units will tend to put pressure on high-cost existing plants
to adopt the lower cost formulations and/or processes. This pressure
will not occur until the coating formulations and equipment have been
in use for some time, have passed the "demonstrated" phase, and are
well on the way to becoming industry standards. It is evident that
existing units can convert on a piecemeal basis as their customers'
specifications change. The number of facilities that may have to
convert is shown on Table 9-17. However, no significant number of
closures are expected as a result of the NSPS.
9.2.2.6 Small Business Effects. The Regulatory Flexibility Act
requires that special consideration be given to the impacts of all
proposed regulations affecting small businesses. The Small Business
Administration (SBA) sets the standards for classifying a business as
small. If 20 percent of the small firms in a regulated industry will
incur a significant adverse economic impact then a Regulatory Flexibility
Analysis must be prepared. Criteria for determining what is a "signif-
icantly adverse economic impact" are
Annualized compliance cost increases total costs of
production by more than 5 percent.
Annualized compliance cost as a percentage of sales for
small firms is more than 10 percentage points higher than
annualized compliance cost as a percentage of sales for
large firms.
Capital costs of compliance represent a significant
portion of capital available to small entities, where
available capital is measured by pretax cash flow minus
9-61
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-------
annual capital expenditures. (The subtraction of capital
expenditures from pretax cash flow is an attempt to model
the capital cost of the regulation to an industry operating
and making investment decisions as usual. To include
normal capital expenditures, either out of need or expan-
sion, as part of the industry's ability to pay, would
represent a maximum, nonrelative measure of capital
availability. While both methods have merit in examining
different forces, we have chosen the former for this
analysis.)
The requirements of the regulation are likely to result
in closures of small entities.
A large percentage of this industry consists of small businesses.
In our analysis, Model Plant A represents a small unit. Model Plant C
is twenty times as large and serves as a surrogate for a large company.
Table 9-7 contains capital and annual operating costs for all the
alternatives analyzed.
None of the regulatory alternatives under active consideration
will increase total production costs more than 5 percent. Annualized
compliance costs as a percentage of sales for small firms are less
than 10 percentage points higher than the annualized compliance costs
as a percentage of sales for large firms. Capital costs for compliance
are generally a small percent of the baseline costs. In the case of
Regulatory Alternative VIII-25/40, the capital" costs for compliance
amount to 25 percent of the baseline costs; yet the savings in produc-
tion costs allow recovery of capital in a matter of months. Thus,
there should be no problem in borrowing funds. Consequently, no
closures because of economic hardship are anticipated. Thus, we can
conclude from this that small business subject to regulation would not
be disproportionately affected.
9.2.2.7 Distribution of Effects. Table 9-18 summarizes the
distributional effects of the NSPS for each regulatory alternative.
Existing suppliers producer surplus is the difference between what
producers actually receive for their products (revenue) and the minimum
they would have accepted on an all-or-nothing basis. The minimum
represents their production costs. Generally, as prices increase,
9-63
-------
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producers' surplus increases; conversely, as prices decrease, producers'
surplus decreases.
Demanders1 consumer surplus is the difference between what con-
sumers actually pay for a given quantity of surface coating services
and the maximum they could have been made to pay on an all-or-nothing
basis. Consumers' surplus increases with price declines and decreases
with price increases.
The algebraic sum of the changes in producers' surplus and changes
in consumers' surplus provides a measure of the net change in welfare
for society or, more specifically, the cost of the NSPS to society. A
positive net change in welfare exclusive of any environmental benefits
is associated with those regulatory alternatives that have negative
costs to society. A negative net change in welfare means the costs to
society are positive with implementation of the NSPS. However, these
net changes do not reflect environmental benefits of regulation.
9.2.3 Cost-Effectiveness Analysis
Estimates of the aggregate annual plastic parts coating emissions
are compared to costs to estimate the cost-effectiveness of each
regulatory alternative. The measure of cost used is the total costs
of the regulation as shown in Table 9-15. The measure of effective-
ness is the reduction in volatile organic compounds (VOC) emissions
from plastic parts coating processes by existing and new suppliers of
coating services. Table 9-19 provides the emission estimate per unit
of output for existing and new technologies.
The capabilities and limitations of cost-effectiveness analysis
are illustrated in Figure 9-10. In panel (a), alternatives A and B
are equal in cost, yet B is more effective and is the clear choice;
hence A is inferior. In panel (b), alternatives A and B are equally
effective, yet B is lower in cost and is again the clear choice;
again, alternative A is inferior. In panel (c), alternative A is both
more costly and less effective than alternative B; it is again inferior
to alternative B. In panel (d), B provides greater emissions reduction
than A but only at higher costs. Neither alternative is inferior. In
panel (e), three alternatives are shown. If it is possible to mix
9-65
-------
TABLE 9-19. VOC EMISSIONS, 10"4 Mg/m2
Market A
Regulatory
Alternative
1-25 (BASELINE)
11-25
111-25
IV-25
V-25
VI-25
VII-25
VIII-25
IX-25
X-25
XI-25
XII-25
XIII-25
XIV-25
XV-25
XVI-25
1-25/40 •
11-25/40
111-25/40
IV-25/40
V-25/40
VI-25/40
VII-25/40
VIII-25/40
IX-25/40
X-25/40
XI-25/40
XII-25/40
XIII-25/40
XIV-25/40
XV-25/40
XVI-25/40
Existing
Facilities
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
7.256
New
Facilities
7.256
6.455
5.737
5.559
4.990
4.196
3.478
3.943
3.293
3.142
2.423
2.916
2.245
2.115
1.396
1.212
6.216
5.415
4.696
4.511
4.374
3.573
2.855
3.519
2.677
2.725
2.006
2.683
1.821
1.883
1.171
0.986
Market
B
Existing New
Facilities Facilities
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.515
4.018
3.572
3.460
3.110
2.614
2.168
2.458
2.055
1.961
1.515
1.819
1.403
1.323
0.877
0.764
3.868
3.371
2.926
2.812
2.726
2.230
1.784
2.196
1.672
1.700
1.254
1.677
1.141
1.181
0.735
0.623

Note: 1 Mg = 2,204.623 Ibs.
9-66
-------
t/TIME
S/TIME
BR1
(a)
B
EMISSIONS
REDUCTIONS/
r 1

C2
S/TIMI
Cl
C2
rA

•

1 r*
• •a
B
EMISSIONS
REDUCTIONS/
TTO < TSTt *} • * * "IB
UK l.iir;^
(b)
• A
X

EMISSIONS
REDUCTIONS/
m TO? TIME
(c)

Figure 9-10. Cost-effectiveness scenarios for regulatory alternatives.
9-67
-------
•J/TIME

C2
Cl
$/TIME

C3
C2

Cl
ER1

(d)
ER2
B
ER1 ER2 ER* ER3

(e)
Figure 9-10 (continued)

9-68
EMISSIONS
REDUCTIONS/
'TIME
EMISSIONS
REDUCTIONS/

' TIME
EMISSIONS
REDUCTIONS/
TIME
-------
regulatory alternatives A and C then B is inferior. This is because
the same emissions reductions, ER2, obtainable with alternative B are
obtainable with a mix of alternatives A and C at a cost of C*. Or,
for the cost of alternative B, C2, greater emissions reduction, ER*,
can be obtained by a mix of alternatives A and C; i.e., requiring some
emitters to employ alternative A, others C. In such situations, B is
an inferior alternative. In panel (f), three minimum cost alterna-
tives are shown.
Table 9-20 and Table 9-21 show the total costs and emissions
reductions for all regulatory alternatives for Market A and Market B
respectively. Table 9-22 shows the total costs and emissions reduction
for Market A and Market B combined. The alternatives are listed in
order of increasing emissions reductions.
Tables 9-23 and 9-24 show the noninferipr alternatives for
Markets A and B, respectively. Regulatory alternatives VIII-25/40,
XI-25/40, and XV-25/40 result in greater emissions reductions at less
cost than all other alternatives in Market A, while alternatives
VIII-25/40, XI-25/40, and XIII-25/40 are the most cost effective in
Market B. For Markets A and B combined, regulatory alternatives
VIII-25/40, XI-25/40, and XV-25/40 are noninferior. Table 9-25 shows
that the incremental cost of VIII-25/40 is -$13,173/Mg of emission
reduction. Regulatory alternatives XI-25/40 and XV-25/40 will result
in a greater reduction of emissions at an additional cost of $3,604
and $90,343 respectively.
9.2.4 Sensitivity Analysis
The economic effects of the NSPS are summarized in Section 9.2.2.
The numbers given are point estimates derived by using estimates and
projections of all the input parameters. They can be used to compare
the 32 regulatory alternatives. The most significant assumption was
that for the elasticity of demand, which is derived from the demand
for business machines. This analysis did not entail a rigorous
development of estimates of the elasticity of demand for surface
coating of plastic business machine parts. We assumed an initial
elasticity of -0.25. All data discussed in Section 9.2.2 are based on
this elasticity of demand.
9-69
-------
TABLE 9-20.
COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
FOR MARKET A
Regulatory
Alternative
Emissions
reduction,
Mg/yr
Total coat
of regulation
$10§/yr
Average cost
per enission
reduction,
$/Mg
1-25 (BASELINE)
11-25
111-25
1-25/40
VI-25
IV-25
V-25
IV-25/40
VII-25
11-25/40
XII-25
IX-25
IX-25/40
XIV-25
XIII-25
XIII-25/40
XV-25
XVI-25
XVI-25/40
111-25/40
V-25/40
VIII-25
VIII-25/40
VI-25/40
X-25
VII-25/40
XIV-25/40
X-25/40
XII-25/40
XI-25
XI-25/40
XV-25/40

0.00
272.62
444.14
743.25
874.32
934.78
950.92
1055.51
1056.84
1172.88
1209.77
1369.79
1442.69
1449.14
1477.85
1545.50
1638.25
1785.37
1810.95
1995.83
2232.87
2512.63
2814.52
2824.14
3203.91
3480.70
3498.89
3508.57
3615.61
3787.36
4104.28
4849.89

0.00
3.23
1.53
-13.96
2.17
30.26
-1.37
24.38
0.45
-4.71
0.02
29.49
23.64
3.25
14.49
6.98
1.55
30.28
24.33
-9.48
-16.17
-39.18
-58.14
-7.00
-29.43
-12.05
-4.67
-48.22
-13.90
-34.60
-53.48
-9.44

0.00
11853.19
3436.67
-18777.48
2484.55
32371.00
-1444.54
23099.96
427.29
-4018.94
19.62
21531.71
16384.44
2245.71
9804.43
4518.56
946.00
16957.86
13435.11
-4752.07
-7240.66
-15592.92
-20658.52
-2478.02
-9186.04
-3460.66
-1333.52
-13744.42
-3843.76
-9134.89
-13030.51
-1946.49

Note: 1 Mg = 2,204.623 Ibs.
9-70
-------
TABLE 9-21.
COST EFFECTIVENESS OF REGULATORY
FOR MARKET B
ALTERNATIVES
Regulatory
Alternative
Emissions
reduction,
Mg/yr
Total cost
of regulation
$10i/yr
Average cost
per emission
reduction,
$/Mg
1-25 (BASELINE)
11-25
111-25
IV-25
1-25/40
11-25/40
VI-25
V-25
VII-25
IX-25
XII-25
X-25
XIV-25
IV-25/40
XV-25
XVI-25
111-25/40
XIII-25
VI-25/40
V-25/40
XIV-25/40
VIII-25
XI-25
VIII-25/40
IX-25/40
XVI-25/40
VII-25/40
X-25/40
XII-25/40
XV-25/40
XI-25/40
XIII-25/40
0.00
345.73
540.30
619.38
910.40
928.44
1058.31
1159.49
1270.25
1342.44
1452.68
1718.93
1745.93
1750.04
1968.28
2032.20
2038.75
2133.21
2430.49
2706.95
2745.07
3155.71
3454.54
3510.13
3642.46
4045.94
4215.36
4342.80
4385.55
4934.67
5038.70
5231.44
0.00
3.86
1.83
2.94
-10.97
-1.61
2.60
-1.67
0.54
1.67
0.03
-0.67
3.88
-3.24
1.85
2.96
-5.80
-0.73
-3.49
-14.09
-1.58
-9.00
-4.25
-25.17
-5.56
-3.20
-8.66
-13.49
-10.91
-5.75
-19.68
-13.58
0.00
11166.21
3384.43
4744.35
-12051.25
-1730.68
2455.77
-1441.91
426.77
1240.73
17.46
-387.51
2225.15
-1853.67
941.34
1458.12
-2846.29
i -342.00
^1436.94
-5204.44
-573.85
-2852.93
-1230.02
-7171.11
-1526.91
-791.91
-2053.52
-3107.37
-2488.04
-1166.09
-3905.06
-2596.26
Note: 1 Mg = 2,204.623 Ibs.
9-71
-------
TABLE 9-22.
COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
FOR TOTAL INDUSTRY
Regulatory
Alternative
Emissions
reduction,
Mg/yr
Total cost
of regulation
$106/yr
Average cost
per emission
reduction,
$/Mg
1-25 (BASELINE)
11-25
111-25
IV-25
1-25/40
VI-25
11-25/40
V-25
VII-25
XII-25
IX-25
IV-25/40
XIV-25
XV-25
XIII-25
XVI-25
111-25/40
X-25
V-25/40
IX-25/40
VI-25/40
VIII-25
XVI-25/40
XIV-25/40
VIII-25/40
XIII-25/40
XI-25
VII-25/40
X-25/40
XII-25/40
XI-25/40
XV-25/40

0.00
618.36
984.44
1554.15
1653.66
1932.63
2101.33
2110.40
2327.09
2662.46
2712.23
2805.56
3195.07
3606.53
3611.05
3817.57
4034.58
4922.83
4939.81
5085.15
5254.63
5668.33
5856.89
6243.96
6324.65
6776.94
7241.91
7696.06
7851.36
8001.16
9142.98
9784.56

0.00
7.09
3.35
33.20
-24.93
4.77
-6.32
-3.05
0.99
0.05
31.16
21.14
7.14
3.40
13.76
33.24
-15.29
-30.10
-30.26
18.08
-10.49
-48.18
21.13
-6.24
-83.32
-6.60
-38.85
-20.70
-61.72
-24.81
-73.16
-15.19 !

0.00
11469.09
3408.00
21360.96
-15074.43
2468.79
-3007.91
-1443.10
427.01
18.44
11488.50
7534.45
2234.48
943.45
3810.49
8706.91
-3789.04
-6113.82
-6124.84
3554.67
-1996.47
-8500.24
3607.09
-999.54
-13173. 11
-973.71
-5364.10
-2689.93
-7860.79
-3100.67
-8001.47
-1552.91

Note: 1 Mg = 2,204.623 Ibs.
9-72
-------

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To determine the responsiveness of the model to changes in the
assumed elasticity of demand, we conducted a sensitivity analysis
using lower and higher demand elasticities, -0.125 and -0.50, respec-
tively. The results of this analysis are shown in Table 9-26 for
three economic effects.
We also tested a demand elasticity of zero. This effectively
maintains industry quantities at the baseline level of 23.6 x 106 mVyear
and assumes that consumers do not respond to changes in price. (This
approach is used in Chapters 7 and 8 to estimate environmental impacts
and costs.) However, the mix between output from existing and new
facilities may still vary depending on the price of services provided
by new facilities.
For none of the effects are the changes especially significant.
For the range of demand elasticity analyzed (0.0 to -0.50), the
results of our analysis are not particularly sensitive to changes in
demand elasticity. For example, a 50-percent change in demand elas-
ticity resulted in no more than an 8.76-percent change in an economic
effect. Further, the engineering data on capital and annual operation
costs have an estimated range of ±30 percent. Changes of less than
10 percent due to changes in demand elasticity are still within the
±30 percent band for the engineering data used to estimate the economic
effects. Consequently, changes in demand elasticities between -0.125
and -0.50 do not appear to have a significant effect on the outputs of
the economic effects model.
9.3 REFERENCES
1. Scherer, F. M. Industrial Market Structure and Economic Perform-
ance. Chicago, IL, Rand McNally. 1980. pp. 4-7.
2. Statistical Policy Division, Office of Management and Budget.
Standard Industrial Classification Manual. U.S. Government
Printing Office. Washington, D.C. 1972.
3. Ellerhorst, H. Industrial Finishing, pp. 26-32. July 1984.
4. U.S. Department of Commerce, Bureau of Economic Analysis. Survey
of Current Business. Washington, D.C. January 1985. p. 8.
9-77
-------
5. Industrial Finishing. November 1982. p. 100.
6. Plastics in Business Machines Growing. Plastics World. July 1982.
p. 10.
7. Plastics World. September 1982. p. 38.
8. The Sherwin-Williams Company Chemical Coating News. Issue No. 9.
Chicago, IL. Fall 1983. pp. 1-2.
9. U.S. Department of Commerce, Bureau of the Census. 1977 Census
of Manufactures. Washington, D.C. 1980. pp. 34D8-D9, 35F5,
30A18.
10. Memo from Glanville, J., MRI, to Salman, D., EPA:CPB. September 7,
1983. Site visit—Ex-Cell-0 Corporation, Athens, TN.
11. Our Newest High-Tech Export: Jobs. Datamation. May 1983. p. 114.
12. Reference 11. p. 114.
13. America's High-Tech Crisis. BusinessWeek. March 1985. p. 60.
14. Reference 7. p. 40.
15. U.S. Department of Commerce, Bureau of Industrial Economics.
1984 U.S. Industrial Outlook. Washington, D.C. 1984. p. 27-7.
16. U.S. Department of Commerce, Bureau of the Census. Statistical
Abstract of the United States: 1982-1983. Washington, D.C.
1983. p. 421.
17. Reference 12. p. 27-7.
18. Reference 13. p. 454.
19. Reference 12. p. 27-11.
20. Reference 12. p. 27-11.
21. Reference 12. p. 11-3.
22. Reference 12. p. 11-3.
23. Memo from Valiante, L., RTI, to Jenkins, R., EPA:EAB. August 1,
1984. Projected Real Growth Rate of Plastic Business Machine
Parts to 1990.
24. Reference 12. p. 27-6.
25. Reference 12. p. 27-8.
9-78
-------
26. Magnet, M. How to Compete with IBM. Fortune. February 6, 1984.
pp. 58-71.

27. Reference 12. pp. 27-4-27-8.

28. Salter, W. E. G. Productivity and Technical Change. Cambridge
University Press. 1969. pp. 48-82.
9-79
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APPENDIX A
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT

The purpose of this study was to develop a basis for supporting
proposed new source performance standards (NSPS) for the surface coating
of plastic parts for business machines. To accomplish the objectives of
this program, technical data were acquired on the following aspects of
the surface coating of plastic parts for business machines: (1) methods
of coating and types of coatings, (2) the release of VOC emissions into
the atmosphere by these sources, and (3) the types and costs of
demonstrated emission control technologies. The bulk of the information
was gathered from the following sources:
1. Open technical literature;
State, regional, and local air pollution control agencies;
Plant visits;
Industry representatives; and
Equipment vendors.
Significant events relating to the evolution of the background information
document are itemized in Table A-l.
2.
3.
4.
5.
A-l
-------
TABLE A-l. EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
Date Company, consultant, or agency/location
Nature of action
3/3/83 Society of the Plastics Industry, Inc.
New York, N.Y.

3/7/83 IBM Corp., Research Triangle Park, N.C.
3/11/83 Western Electric Co., Inc.
New York, N.Y.

3/25/83 E. I. du Pont de Nemours and Co.,
Wilmington, Del.

3/25/83 The Sherwin Williams Co., Chicago, 111.

4/7/83 Southeastern-Kusan, Inc., Inman, S.C.

6/17/83 U. S. Environmental Protection Agency

8/5/83 Ex-Cell-0 Corp., Athens, Tenn.
8/18/83 E/H Lubricants, Inc., West Lafayette, Ind.
Eastman-Kodak Company, Rochester, N.Y.
Leon Plastics, Grand Rapids, Mich.
Preraix, Inc., North Kingsville, Ohio
Como Plastics, Columbus, Ind.
Craddock Finishing, Evansville, Ind.
Cashiers Plastics, Chandler, Ariz.
E/H Lubricants, Inc., Denver, Colo.
Applied Digital Data Systems, Inc.
Hauppauge, N.Y.
NCR Corp., Dayton, Ohio

8/18/83 Ex-Cell-0 Corp., Athens, Tenn.
8/30/83 MDS-Qantel Corp., Hayward, Calif.
8/31/83 Finishing Technology, Inc.,
Santa Clara, Calif.
9/1/83 E.M.A.C., Inc., Oakland, Calif.
1/12/84 Columbus Industries, Ashville, Ohio
Letter requesting information about the
surface-coated plastic parts industry.

Plant visit to gather background information
on the methods used to coat plastic parts
for business machines.

Letter requesting information about coatings
applied to plastics.

Plant visit to gather background information
on the methods used to coat plastic parts
for business machines.

Memo authorizing Phase II-"Draft Development
of New Source Performance Standards for
Surface Coating of Plastic Parts for
Business Machines."

Letter transmitting EPA/ESED procedures for
safeguarding confidential business
information.

Section 114 information request.
Plant visit to gather background information
on the methods used to coat plastic parts
for business machines.

Plant visit to gather background information
on the methods used to coat plastic parts
for business machines.

Plant visit to participate in an open house
demonstration of the application of higher
solids coatings.

Letter requesting estimated capital and
annualized costs of dry filter media for
model plants.
(continued)
A-2
-------
TABLE A-l. (continued)
Date
Company, consultant, or agency/location
Nature of action
4/10/84 Texas Instruments, Inc., Houston, Tex.
7/11/84 Mailed to industry members, selected
equipment vendors and consultants

7/11/84 Red Spot Paint and Varnish Co.,
Evansville, Ind.

Emerson and Cuming, Canton, Mass.
Emhart Corp., Torrance, Calif.
Graham Magnetics, Inc. , North Richmond
Hills, Tex.
The Sherwin-Williams Co., Chicago, 111.

Reliance Universal, Inc. r Louisville, Ky.

7/19/84 General Electric Co., Schenectady, N.Y.

7/31/84 E.M.A.C. , Inc., Oakland, Calif.

10/11/84 General Electric Co., Chelsea, Mass.

10/24/84 E.M.A.C., Inc., Oakland, Calif.

3/7/85 Mailed to members of the Working Group

4/10/85 CTI--E/M Lubricants, Inc., New Brighton,
Minn.
5/2/85 U. S. Environmental Protection Agency,
National Air Pollution Control
Techniques Advisory Committee (NAPCTAC),
and industry representatives

5/10/85 Mailed to members of the Steering
Committee
Plant visit to gather background information
on the use of electrostatic spray equipment
for coating plastic parts for business
machines.

Draft BID Chapters 3, 4, 5, and 6 and request
for comment.

Letter requesting coating samples and
formulation of 225 WLE 9775 and 230 WLE
10066 for Method 24 analysis.

Letter requesting coating samples and formu-
lation of Eccocoat19 CC-33W for Method 24
analysis.

Letter requesting coating samples and formu-
lation of BOSTIK 695-50-1 for Method 24
analysis.

Letter requesting coating samples and formu-
lation of Cobaloy® P-212 Type 1AHS,
Cobaloy® P-212 Type 3 (waterborne), and
Cobaloy® P-212 Type IB for Method 24
analysis.

Letter requesting coating samples and formu-
lation^of Polane T, Polane HST, and
Polane H for Method 24 analysis.

Letter requesting coating samples and formu-
lation of Rel-Star for Method 24 analysis.

Letter requesting coating samples and formu-
lation of Emilux® 1832 for Method 24
analysis.

Letter transmitting finalized report of plant
visit and requesting results and performance
report of Sherwin-Williams Polane H demon-
stration and general information about
E.M.A.C. operations.

Letter requesting samples and formulation
data of Emilux 1832 coating for Method 24
analysis.

Site visit to attend a seminar and open-house
demonstration of the application of low-VOC-
content coatings.

Working Group mailout.

Plant visit to gather background information
on various methods of electromagnetic/radio
frequency interference shielding and
exterior coating used to coat plastic parts
for business machines.

NAPCTAC Meeting.
Steering Committee mailout.
(continued)
A-3
-------
TABLE A-l. (continued)
Date Company, consultant, or agency/location
Nature of action
7/26/85 Bee Chemical Company, Lansing, 111.
Graham Magnetics, Inc., North Richland
Hills, Tex.
Letter requesting coating samples and _
formulation of 8-85®, R-65 , and R-73's for
Method 24 analysis.

Letter requesting coatina samples and
formulation of Cobaloy P-212 type 4,
Cobaloyf P-212 type 4A, and reformulated
Cobaloy® P-212 type 4A for Method 24
analysis.
A-4
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

This appendix consists of a reference system which is cross-indexed
with the October 21, 1974, Federal Register (39 FR 37419) containing the
Agency guidelines concerning the preparation of environmental impact
statements. This index can be used to identify sections of the document
which contain data and information germane to any portion of the Federal
Register guidelines.
B-l
-------
TABLE B-1. CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document
1.
BACKGROUND AND SUMMARY OF
REGULATORY ALTERNATIVES

Summary of regulatory alternatives
Statutory basis for proposing
standards
Industries affected by the
regulatory alternatives
Specific processes affected by
the regulatory alternatives
2. REGULATORY ALTERNATIVES

Control techniques

Regulatory alternatives
The regulatory alternatives from
which standards will be chosen
for proposal are summarized
in Chapter 1, Section 1.1.

The statutory basis for proposing
standards is summarized in
Chapter 2, Section 2.1.

A discussion of the industries
affected by the regulatory
alternatives is presented in
Chapter 3, Section 3.1. Further
details covering the business
and economic nature of the
industry are presented in
Chapter 9, Section 9.1.

The specific processes and
facilities affected by the
regulatory alternatives are
summarized in Chapter 1,
Section 1.1. A detailed technical
discussion of the processes
affected by the regulatory
alternatives is presented in
Chapter 3, Section 3.3.
The alternative control techniques
are discussed in Chapter 4.

The various regulatory alterna-
tives are defined in Chapter 6,
Section 6.2. A summary of the
major alternatives considered is
included in Chapter 1, Section 1.1.
(continued)
B-2
-------
TABLE B-l (continued)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document
3.
ENVIRONMENTAL IMPACT OF THE
REGULATORY ALTERNATIVES

Primary impacts directly
attributable to the regulatory
alternatives
Secondary or induced impacts
4. OTHER CONSIDERATIONS
The primary impacts on mass
emissions and ambient air quality
due to the alternative control
systems are discussed in
Chapter 7, Sections 7.1, 7.2, 7.3,
7.4, and 7.5. A matrix
summarizing the environmental
impacts is included in Chapter 1.

Secondary impacts for the various
regulatory alternatives are
discussed in Chapter 7,
Sections 7.1,, 7.2, 7.3, 7.4, and
7.5.

A summary of the potential
adverse environmental impacts
associated with the regulatory
alternatives is included in
Chapter 1, Section 1.2, and
Chapter 7. Potential socio-
economic and inflationary impacts
are discussed in Chapter 9,
Section 9.2. Irreversible and
irretrievable commitments of
resources are discussed in
Chapter 7, Section 7.6.
B-3
-------
-------
APPENDIX C
EMISSION SOURCE TEST DATA

The numerical emission limits were not developed from emission test
data. Instead, they were based on the determinations of the VOC content
of the coating or shielding material and the assumption that all
volatile organic compounds are emitted into the atmosphere.
The solvent content of the coatings was based on data provided by
coating manufacturers and is similar to that which would have been
obtained using Reference Method 24. EPA has collected samples of
several materials and will determine the VOC content of these samples
using Reference Method 24.
C-l
-------
-------
APPENDIX D - EMISSION MEASUREMENT AND MONITORING

This appendix describes the measurement method experience that was
gained during the emission testing portion 9f this study, recommended per-
formance test procedures, and potential continuous monitoring procedures.
The purposes of these descriptions are to define the methodologies used to
collect the data, to recommend potential procedures to demonstrate compliance
with a new source performance standard, and to discuss alternatives for
monitoring either emissions or process parameters to indicate continued
compliance with that standard.

D.I EMISSION MEASUREMENT TEST PROGRAM AND METHODS

No emission source testing in the plastic parts coating industry was
conducted by the Emission Standards and Engineering Division (ESED) of the
Environmental Protection Agency (EPA) as part of the background support
study for the new source performance standard for this industry. However,
testing had been conducted earlier by ESED/EPA in similar surface coating
industries, and similar test procedures would be applicable for the plastic
parts coating industry.

D.I.I Coating Analysis Testing

Extensive analysis of coating samples from other surface coating
industries has been done. Coating samples were received from paint and
ink manufacturers and users in the following industries: automobile and
light-duty truck, metal coil, can, large appliances, pressure-sensitive
tapes and labels, magnetic tape, flexible vinyl coating and polymeric
D-l
-------
coating. The coatings types included high-solvent, high-solids, waterborne,
and solvent-waterborne coatings. These sample coatings encompassed the
range of coatings expected in the respective industries. All the samples
were analyzed using EPA Reference Method 24.
Because the expected composition of plastic parts coatings is similar
to the coatings tested, Method 24 should be applicable to the plastic
parts coating industry.
D.I.2 Emission Source Testing Programs
Although no plants which coat plastic parts were tested, emission
tests for volatile organic compounds (VOC) were conducted at several
plants in similar coating industries: automobile and light-duty truck,
metal coil, can, pressure-sensitive tapes and labels, publication rotogravure,
flexible vinyl coating, and polymeric coating. Because similar test
procedures would be applicable to plastic parts coating, details of these
test programs in other industries are discussed below.
For each individual facility that was tested, the test procedures and •
approaches varied somewhat due to different data needs and plant design
configurations. In general, the purpose of the testing programs was to
characterize the VOC emissions to the atmosphere and the control efficiency
of the vapor capture and processing systems, as well as the overall solvent
usage, end distribution, and material balance throughout the entire
coating process. The field testing was usually much more comprehensive
than the performance test procedures specified in the applicable regulations
for these industries in order to evaluate various testing approaches and
methods and to gather useful auxiliary information to better understand
the process operation.
D.I.3 Stack Emission Testing Conducted
D.I.3.1 Testing Locations. Gas streams that were tested in other
coating industries for VOC concentrations and flow rate included: inlets
and outlets of vapor processing devices; exhaust streamers from mixing
equipment and/or storage tanks; uncontrolled exhaust streams venting
directly to the atmosphere; intermediate process streams such as hood
exhausts and drying oven exhausts venting to other process units. From the
concentration and flow rate results, the VOC mass emissions or mass flow
rate in each strean could be calculated. Not all of these streams were
D-2
-------
tested at each plant. The streams selected for sampling at a particular
plant depended on the data needs of that particular industry testing
program. These gas streams were usually in vents that were suitable for
conventional EPA stack emission measurement techniques, and these measurement
approaches are described in this section.
If there were emissions that were not collected and vented through
stacks suitable for conventional testing, then ambient VOC survey techniques
had to be adopted. (An example would be open doorways or small ducts.) These
nonconventional measurement techniques are described in a later section, D.I.5.
D.I.3.2 Flow Measurements. During ESED/EPA's field testing programs,
Reference Methods 1, 2, 3, and 4 were used to determine the volumetric
flow rate of the gas streams being sampled. Because all the stacks or
ducts that were tested had diameters of at least 12 inches, Methods 1 and
2 were applicable, and alternative flow rate measurement techniques were
not required. The volumetric flow rates were determined on either a dry
or wet basis, depending on whether the corresponding YOG concentration method
used for that site measured VOC concentrations under actual conditions
(wet basis) or dry conditions.
Reference Method 1 was used to select the sampling site along the duct
or stack, and to determine the number of sampling points on the cross-sectional
area inside the duct. Method 2 was used to measure gas velocity. This
method is based on the use of an S-type pi tot tube to traverse the duct
cross-section to calculate an average gas velocity. To determine the gas
stream molecular weight and density, as required for Method 2, the fixed
gases composition and moisture content are needed. The fixed gas composition
(Og, C02, CO, N£) was usually determined by an Orsat analysis procedure
detailed in Method 3. Sometimes, however, the molecular weight of the
vent gases was assumed to be the same as ambient air. This was a valid
assumption when no combustion sources were involved and the hydrocarbon
concentrations in the stream were low. Gas stream moisture was measured
following Method 4, or with a wet bulb/dry bulb approach. The less precise
wet bulb/dry bulb technique was acceptable because the moisture value was
not usually a crucial parameter in these tests. Also, the moisture content
was not expected to differ from ambient conditions unless combustion sources
were involved. The moisture content is used to adjust the molecular weight
in a calculation step in Method 2, and to adjust the flow rates to a dry
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basis if needed. Using the duct area, the gas volumetric flow rate was
then calculated.
If the flow rate in a vent was suspected to be unsteady ana varied
significantly during a test run, then Method 2 was modified to give an
indication of the continuous flow rate. The pi tot tube was left in the
duct at a single representative sampling point so that any changes in the
flow rate could be monitored.
D.I.3.3 Concentration Measurements. The VOC concentration in each
stack was determined using one or more of the following methods:
0 Reference Method 25 (M25)
0 Flame lonization Analyzer (FIA)
0 Reference Method 25A (M25A)
0 Modified calibration procedures following a more general
method detailed in an EPA guideline document (GENERAL FIA)
0 Continuous measurements using direct extraction (CONT/FIA)
0 Time-Integrated bag samples (BAG/FIA)
0 Reference Method 18 - Gas Chromatograph (GO with flame ionization
detector
0 Time-Integrated bag samples (BAG/GC)
' ° Grab flask or syringe samples (GRAB/GO
It should be noted that at the time of the testing, many of these methods had
not been finalized, so preliminary versions were followed. However, the later
changes to these methods were not significant and would not have affected the
test results. Usually, two of the VOC measurement procedures were run
simultaneously. This was done in order to characterize the emissions in
more detail, as well as to aid in selecting an appropriate test method.
The direct extraction FIA method was used at sites which were convenient
and not in hazardous areas. The direct FIA had the advantage that, with
continuous measurements, minor process variations could be noted. Also, once
it was set-up, it was relatively inexpensive to run it for a long time
period, and thus, changes in emissions due to process variations could be
easily noted.
The other methods could be used at any sampling location, including
sites in explosive atmospheres or remote locations. When the time-integrated
sampling methods were used (M25, BAG/FIA, BAG/GC), the sample was collected
for a 45- to 60-minute time period. Because of its complex analysis procedure,
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the Method 25 samples had to be analyzed later in the laboratory. The inte-
grated bag samples, however, were analyzed as soon as possible (within 24
hours) on-site by either a FIA or GC method.
The FIA's were usually calibrated with propane, although sometimes they
were also calibrated with the solvent being used in the coating process,
(GENERAL FIA). The GC's were calibrated with each component that was known
to be in the solvent mixture being used.
The results from the different FIA sampling approaches should be
equivalent, provided they are compared for the same time periods. The Method
25 results differed somewhat from the results of the FIA. The differences
were probably due to the fact that the Method 25 procedure measures all
carbon atoms equally, while the FIA detector has a varying response ratio
for different organic compounds. The difference in results would be most
pronounced when a multi-component solvent mixture is used.
The results from the two GC sampling approaches would necessarily be
different because of the different sampling time periods. The results from'
a GC analysis are reported as concentrations for each individual compound, and
thus cannot be compared directly to the FIA results. The FIA is calibrated
with one compound and the total hydrocarbon concentration is reported as one
number on the basis of that compound. Also, the FIA detector has a varying
response ratio to different organic compounds, so again the difference in
results between the GC and FIA would be most pronounced when a multi-component
solvent mixture is used.
D.I.4 Liquid Solvent Material Balance Testing Conducted
The EPA did not directly conduct any long-term liquid solvent material
balance tests; however, detailed records were obtained from three plants in
two industries and EPA scrutinized their procedures. In all cases, the
vapor recovery device was a carbon absorber. The solvent used by the plant
was compared to the solvent recovered (usually on a weekly or monthly
basis), in order to obtain an overall control efficiency, combining capture
and recovery efficiencies. At one plant in the pressure-sensitive tapes
and labels industry, the amount of solvent recovered was determined by
reading the level in the solvent recovery tank at the carbon adsorber. The
amount of solvent used was determined from plant purchasing, inventory, and
production records. At two plants in the publication rotogravure industry,
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In-line meters measured the amount of solvent directed to each printing
line and the recovered solvent returned to the solvent storage tank.
D.I.5 Ambient Surveys and Fugitive Emission Characterization
Ambient measurements were conducted during some test series. Open
doorways and windows were monitored periodically to estimate the mass
flux of VOC into and out of the coating area. The flow rate through openings
was measured with a hand-held velometer or a hot-wire anemometer (4 to 9 points
were sampled per opening). Concentration was measured with a portable
combustible gas detector which generally conformed to Reference Method 21
specifications.
Ambient VOC concentration levels in the coating area were measured
periodically during the testing period. The surveys were conducted
throughout the room. If vertical stratification were suspected, surveys were
conducted at various heights.
Surveys were also made of the VOC concentrations and flow rates into
hood intakes above coating, embossing, or mixing operations, in order to
estimate and characterize the fugitive VOC's which were drawn into the
hooding exhaust stack. VOC concentration and flow measurements were made
at representative spots around intake hoods as close to the intake as the
physical equipment setup permitted.
Eight-hour exposure sampling was conducted during some test programs.
Following a NIOSH ambient sampling procedure, ambient air samples were
drawn through carbon tubes. Analysis consisted of extraction in carbon
disulfide and liquid analysis by gas chromatograph for speciation of the
solvent components used in the coatings.
D.I.6 Solvent Sample Analysis
Some plants mix their coatings on-site from raw materials. Samples
of the solvent (or mixture of solvents) were obtained and analyzed for
speciation by direct injection into a gas chromatograph. The results
from these analyses indicated whether the solvent (or solvent mixture)
being used matched the plant's formulation data.
Samples of recovered solvent from carbon adsorbers were also obtained
and analyzed in order to compare the composition of the recovered solvent
to that of the new solvent.
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D.I.7 Wastewater Sample Analysis
If the solvents being used were miscible in water, then the
recovered solvent from a steam-generated carbon adsorber was mixed with
water and was separated in a distillation step. Wastewater samples
were collected from various points in the carbon adsorption/distillation
system. The water samples were analyzed for compound speciation and
total organic carbon using standard laboratory water analysis procedures.
The results from this determination were used to characterize the
operation of the carbon adsorber and applied to the solvent material
balance calculations.
0.1.8 Product Sample Analysis
Product samples were collected and analyzed for residual solvent
content in two industries. The results from this determination were
applied to the solvent material balance calculations. In general, the
results from the residual solvent content analyses were unreliable, and
the small number of samples taken may not have been representative. Thus,
the results were only viewed as general background or indicators.
In the pressure sensitive tapes and labels industry, final tape
samples were collected and analyzed for residual solvent, using ASTM
F 151-72 "Standard Test Method for Residual Solvents in Flexible Barrier
Material." This method only provided an index for comparing solvent
levels and was inappropriate for the true measurement of the mass of
residual solvent.
In the flexible vinyl printing and coating industry, product samples
of the vinyl wallcovering were obtained before and after the embosser
and analyzed for solvent content. The test procedure was an adaptation
of NIOSH ambient carbon tube measurement techniques. The product samples
were put in a heated container and air was drawn across the container and
then through a carbon tube, which collected the organics. The carbon
tubes were analyzed for compound speciation by a gas chromatograph, in
the same manner as ambient sample carbon tubes. This product sampling
and analysis was a preliminary test procedure. The results were in a
lower range than expected, but there is no way to independently verify
the results.
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D.2 PERFORMANCE TEST METHODS
Many different approaches, test methods, and test procedures can be used
to characterize volatile organic compound (VOC) emissions from industrial
surface coating facilities. The particular combination of measurement methods
and procedures to be used depends upon the format of the standard and test
procedures specified in the applicable regulation.
General testing approaches are:
1. Analysis of coatings.
2. Direct measurement of emissions to the atmosphere from stacks.
3. Determination of vapor processing device efficiency.
4. Determination of vapor capture system efficiency.
5. Determination of overall control efficiency based on liquid solvent
material balance.
6. Survey of fugitive emissions.
D.2.1 Performance Testing of Coatings
D.2.1.1 Analysis of Coatings
Recommended Method. EPA Reference Method 24 is the recommended
method for the analysis of coatings. This method combines several American
Society of Testing and Materials (ASTM) standard methods to determine the
volatile ma-tter content, water content, density, volume solids, and weight
solids of inks and related surface coatings. These parameter values are
combined to calculate the VOC content of a coating in the units specified
in the applicable regulation.
Reference Method 24A is similar in principle to Method 24, but some
of the analytical steps are slightly different and the results would differ.
It was developed specifically for publication rotogravure printing inks and
contains specific analytical steps which were already widely used in that
industry. Thus, Reference Method 24A is not recommended for analysis of
coatings for plastic parts.
Volatile Matter Content (Wv). The total volatile content of a
coating is determined by using ASTM D 2369-81, "Standard Test Method for
Volatile Content of Coatings." This procedure is applied to both aqueous
and nonaqueous coatings. The result from this procedure is the volatile
content of a coating as a weight fraction.
Water Content(Ww). There are two acceptable procedures for
determining the water content of a coating: (1) ASTM D 3792-80, "Standard
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Test Method for Water Content of Water-Reducible Paints by Direct Injection
into a Gas Chromatograph," and (2) ASTM D 4017-81, "Standard Test Method
for Water in Paints and Paint Materials by the Karl Fischer Titration Method."
This procedure is applied only to aqueous coatings. The result is the
water content as a weight fraction.
Organic Content (W0). The volatile organic content of a coating
(as a weight fraction) is not determined directly. Instead, it is determined
indirectly by substraction from the total volatile content and the water
content values.
W0 = Wv - Ww
Solids Content (Ws). The solids content of a coating (as a weight
fraction) is also determined indirectly using the previously determined
values:
Ws = 1 - Wv = 1 - W0 - Ww
Volume Solids (Vs). There is no reliable, accurate analytical
procedure that is generally applicable to determine the volume solids of
a coating. Instead, the solids content (as a volume fraction) is calculated
using the manufacturer's formulation data.
Coating Density (Dc). The density of coating is determined
using the procedure in ASTM D 1475-60 (Reapproved 1980), "Standard Test
Method for Density of Paint, Varnish, Lacquer, and Related Products."
Cost. The estimated cost of analysis per coating sample is:
$50 for the total volatile matter content procedure; $100 for the water
content determination; and $25 for the density determination. Because
the testing equipment is standard laboratory apparatus, no additional
purchasing costs are expected.
Adjustments. If negligibly photochemically reactive solvents
are used in the coatings, then standard gas chromatographic techniques
approved by the Administrator may be used to identify and quantify these
solvents. The results of Reference Method 24 may be adjusted to subtract
these solvents from the measured VOC content.
D.2.1.2 Sampling and Handling of Coatings. For Method 24 analysis of
a coating, a 1-liter sample should be obtained and placed in a 1-liter con-
tainer. The head-space in the container should be as small as possible so
that organics in the coating do not evaporate and escape detection. The
coating sample should be taken at a place that is representative of the
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coating being applied. Alternatively, the coating may be sampled in the
mixing or storage area while separate records are kept of dilution solvent
being added at the coating heads. Some plastic parts coatings have an
ingredient (usually a resin) that cause the coating to "set" within a short
time period. Samples of these coatings need to be taken before the "setting
agent" has been added. Two- or three-component coatings may require separate
sampling and analysis of each component.
The coating sample should be protected from direct sunlight, extreme
heat or cold, and agitation. There is no limitation given in Method 24
for the length of time between sampling and analysis.
D.2.1.3 Weighted Average VOC Content of Coatings. If a plant uses all
low-solvent coatings (as specified in the applicable regulation), then
each coating simply needs to be analyzed following Method 24. However, if
a plant uses a combination of low-and high-solvent coatings, the weighted
average VOC content of all the coatings used over a specified time period
needs to be determined. Depending on the format of the standard, the average
is weighted by the volume or mass of coating solids.
In addition to the Method 24 formulation information, the amount
of each coating used must be determined. The EPA has no independent test
procedure to determine the amount of coating used, and instead it is recom-
mended that plant inventory and usage records be relied upon. Most plants
already keep detailed records of amounts of coatings used. Thus, no additional
effort or cost is expected to be required to attain coating usage.
D.2.2 Stadk Emission Testing
D.2.2.1 Testing Locations. Stack emission testing techniques would be
needed to measure the VOC concentration and gas flow rate in stacks and
ducts such as: inlets and outlets of vapor processing devices; exhaust
streams from mixing equipment and/or storage tanks; uncontrolled exhaust
streams venting directly to the atmosphere; intermediate process streams
such as hood exhausts and drying oven exhausts venting to other process
units. The particular streams to be measured depends upon the applicable
regulation.
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D.2.2.2 Use of Test Results. The results from the VOC concentration
measurement and flow rate measurement can be combined and used In many
ways. If a regulation Is on a concentration basis, then only VOC concen-
tration measurement Is needed and the result can be used directly. If the
regulation is on a mass emission basis (i.e., mass emitted per unit of
production; or mass emitted per unit of time), then the concentration and
flow rate results are combined to calculate the mass flow rate. If the
regulation is on an efficiency basis, then mass flow rate is determined for
each of the streams being compared and the efficiency is calculated straight-
forwardly .
The performance test procedure in the applicable regulation will
define the test length and the conditions under which testing is acceptable,
as well as the way the reference test method measurements are combined to
attain the final result.
D.2.2.3 Overall Control Efficiency. Performance test methods and
procedures are used to determine the overall control efficiency of the
add-on pollution control system. The add-on control system is composed of
two parts: a vapor capture system, and a vapor processing device (carbon
adsorber, condenser, or incinerator). The control efficiency of each
component is determined separately and the overall control efficiency is
the product of the capture system and processing device efficiencies.
(Note: This measured overall control efficiency will not reflect control
or emission reduction due to process and operational changes)
D.2.2.4 Processing Device Efficiency. The three types of processing
devices that are expected to be used in the plastic parts coating industry
are carbon adsorbers, condensers, and incinerators. The test procedure to
determine efficiency is the same for each control technology.
To determine the efficiency of the emission processing device, the VOC
mass flow rate in the inlet and outlet gas streams must be determined. To
determine the mass of VOC in a gas stream, both the concentration and flow
rate must be measured. The recommended methods and the reason for their
selection are discussed later in sections D.2.2.7 and D.2.2.8.
D.2.2.5 Capture System Efficiency. The efficiency of the vapor
capture system is defined as the ratio of the mass of gaseous VOC emissions
directed to the vapor processing device to the total mass of gaseous VOC
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emissions from the plastic parts coating line. The mass of VOC in each
applicable vent is determined by measuring the concentration and the flow
rate using standard EPA test methods. The recommended methods and the
reason for their selection are discussed later in sections D.2.2.7 and
D.2.>2.8.
In order to determine capture efficiency, all fugitive VOC emissions
from the coating area must be captured and vented through stacks suitable
for testing. Furthermore, the coating line being tested should be isolated
from any fugitive VOC emissions originating from other sources. All
doors and other openings through which fugitive VOC emissions might
escape would be closed.
One way to isolate the coating line from other VOC emission sources
and to capture and vent all fugitive emissions from the coating line is to
construct a temporary enclosure with a separate vent around those portions
of the coating line (e.g. flash-off area) where fugitive emissions normally
occur. The temporary enclosure should be ventilated at a rate proportional
to that of the building in which the enclosure is housed in order to duplicate
closely the normal emissions profile. Although this method of measuring
capture efficiency may not produce conditions identical to normal operation,
the rate of generation of "fugitive" emissions within the temporary
enclosure will tend to be lower than without the enclosure. The enclosure
walls will reduce cross drafts resulting in a conservatively high estimate
of capture efficiency.
Instead of requiring a performance test, a regulation may require a
specific equipment configuration in order to ensure a high capture efficiency.
For example, the applicable regulation may specify a total enclosure around
the coater or sealed lids and a closed venting system for coating mix equip-
ment. To ensure that these equipment specifications are met, visible inspec-
tions or Method 21 leak detection surveys can be conducted. However,
ESED/EPA has no experience using Method 21 for detecting such leaks in the
surface coating industries, and thus cannot recommend a leak concentration
level to be used in evaluating the performance of various pieces of capture
equipment.
D.2.2.6 Stack Emission Testing - Time and Cost. The length of a
performance test is specified in the applicable regulation and is selected
to be representative for the industry and process being tested. The length
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of a performance test should be selected to be long enough so to account
for variability in emissions due to up and down operation times, routine
process problems, and different products. Also, the performance test time
period should correspond to the cycles of the emission control device.
Coating line operations are intermittent; there are often long time
periods between runs for cleanup, setup, and color matching, so the total
length of a performance test could vary from plant to plant. In general,
a performance test would consist of three to six runs, each lasting from
1/2 to 3 hours. It is estimated that for most operations, the field
testing could probably be completed in 2 to 3 days (i.e., two or three
8-hour work shifts) with an extra day for setup, instrument preparation,
and cleanup.
The cost of the testing varies with the length of the test and the
number of vents to be tested: inlet, outlet, intermediate process, and
fugitive vents. The cost to measure VOC concentration and flow rate is
estimated at $6,000 to $10,000 per vent, excluding travel expenses.
D.2.2.7 Details on Gas Volumetric Flow Measurement Method.
Recommended methods. Reference Methods 1, 1A, 2, 2A, 2C, 20, 3
and 4 are recommended as appropriate for determination of the volumetric
flow rate of gas streams.
Large stacks with steady flow. Methods 1 and 2 are used in
stacks with steady flow and with diameters greater than 12 inches.
Reference Method 1 is used to select the sampling site, and Reference
Method 2 measures the volumetric flow rate using a S-type pi tot tube
velocity traverse technique. Methods 3 and 4 provide fixed gases analysis
and moisture content, which are used to determine the gas stream molecular
weight and density in Method 2. The results are in units of standard
cubic meters per hour.
Small ducts. If the duct is small (less than 12 inches diameter)
then alternative flow measurement techniques will be needed using Method
2A, Method 2D, or Methods 2C and 1A. Method 2A uses an in-line turbine
meter to continuously and directly measure the volumetric flow. Method 2D
uses rotameters, orifice plates, anemometers, or other volume rate or
pressure drop measuring devices to continuously measure the flowrate.
Methods 1A and 2C (in combination) modify Methods 1 and 2 and use a small
standard pi tot tube tranverse technique to measure the flow in small ducts,
and apply when the flow is constant and continuous.
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Unsteady flow. If the flow in a large duct (greater than 12 inches
diameter) is not steady or continuous, then Method 2 may be modified to
continuously monitor the changing flow rate in the stack. A continuous
1-point pi tot tube measurement is made at a representative location in the
stack. For small ducts with unsteady flow, continuous measurement with
Method 2A or 2D is recommended.
Adjustment for moisture. The results do not need to be adjusted
to dry conditions (using Method 4 for moisture) if the VOC concentrations
are measured in the gas stream under actual conditions; that is, if the
YOC concentrations are reported as parts of VOC per million parts of
actual (wet) volume (ppmv). If the concentrations are measured on a dry
basis (gas chromatographic techniques or Method 25) then the volumetric
flow rate must correspondingly be adjusted to a dry basis.
D.2.2.8 Details on VOC Concentration Measurement Method.
Method 25A. The recommended VOC measurement method is Reference
Method 25A, "Determination of Total Gaseous Organic Concentration Using A •
Flame lonization Analyzer"(FIA). This method was selected because it measures
the expected solvent emissions accurately, is practical for long-term,
intermittent testing, and provides a continuous record of VOC concentration.
A continuous record is valuable because of coating line and control device
fluctuations. Measurements that are not continuous may not give a representa-
tive indication of emissions. The coating lines in this industry may
operate intermittently, and the vent concentrations may vary significantly.
Continuous measurements and records are easier to use for intermittent
processes, and the short-term variations in concentration can be noted.
The continuous records are averaged or integrated as necessary to obtain an
average result for the measurement period.
Method 25A applies to the measurement of total gaseous organic concen-
tration of vapors consisting of alkanes, and/or arenes (aromatic hydrocarbons).
The instrument is calibrated in terms of propane or another appropriate
organic compound. A sample is extracted from the source through a heated
sample line and glass fiber filter and routed to a flame ionization analyzer
(FIA). (Provisions are included for eliminating the heated sampling line
and glass fiber filter under some sampling conditions.) Results are reported
as concentration equivalents of the calibration gas organic constitutent or
organic carbon.
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Instrument calibration is based on a single reference compound. For the
plastic parts coating industry the recommended calibration compound is propane
or butane. (However, if only one compound is used as the sole solvent at a
plant, then that solvent could be used as the calibration compound.) As a
result, the sample concentration measurements are on the basis of that
reference compound and are not necessarily true hydrocarbon concentrations.
The response of an FIA is proportional to carbon content for similiar compounds.
Thus, on a carbon number basis, measured concentrations based on the reference
compound are close to the true hydrocarbon concentrations. Also, any minor
biases in the FIA concentration results are less significant if the results
will be used in an efficiency calculation — both inlet and outlet measure-
ments are made and compared — and biases in each measurement will tend to
cancel out. For calculation of emissions on a mass basis, results would be
nearly equivalent using either the concentration and molecular weight based
on a reference gas or the true concentration and true average molecular
weight of the hydrocarbons.
The advantage of using a single component calibration is that costly
and time consuming chromatographic techniques are not required to isolate
and quantify the individual compounds present. Also, propane and butane
calibration gases are readily available in the concentration ranges needed
for this industry.
The solvents commonly used in coatings in this industry are methyl-ethyl-
ketone (MEK), xylene, toluene, glycol ethers, glycol ether acetates, and
tetrahydrofuran (THF). Most plants use a mixture of different compounds for
solvent. Since the solvent mixtures may vary from day to day and from plant
to plant, there is no standard solvent mixture to use for calibration.
Also, the individual compounds in the mixture will evaporate and be controlled
at different rates, so the gaseous VOC mix in the exhaust stream is not the
same mix as the original multi-component liquid solvent. Furthermore, if
incineration is used, any semi-destructed gaseous compounds at the incinerator
outlet will be different from the compounds in the original solvent mixture.
Thus, there is no advantage in calibrating the FIA with the mixture of
solvents being used.
The analysis technique using an FIA measures total hydrocarbons including
methane and ethane, which are considered non-photochemically reactive, and
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thus not VOC's. Due to the coating solvent composition, little methane or
ethane is expected in the gas streams so chromatographic analysis is not
needed nor recommended to adjust the hydrocarbon results to a nonmethane,
nonethane basis.
Other Methods. Three other VOC concentration measurement methods
were considered (and rejected) for this application: Method 18, Method 25B,
and Method 25.
Method 18. Gas chromatograph (GO analysis on integrated bag
samples following Method 18 was considered because results would be on the
basis of true hydrocarbon concentrations for each compound in the solvent
mixture. However, the BAG/GC sample technique is not a continuous measurement
and would be cumbersome and impractical because of the length of the testing.
Also, it would be costly and time consuming to calibrate for each compound,
and there is little advantage or extra accuracy gained from the GC approach.
Method 25B. Method 25B, "Determination of Total Gaseous Organic
Concentration Using a Nondispersive Infrared Analyzer," is identical to Method
25A except that a different instrument is used. Method 25B applies to the
measurement of total gaseous organic concentration of vapor consisting pri-
marily of alkanes. The sample is extracted as described in Method 25A and
is analyzed with a nondispersive infrared analyzer (NDIR). Method 25B was
not selected because NDIR analyzers do not respond as well as FIA's to all
of the solvents used in this industry. Also, NDIR's are not sensitive in
low concentration ranges (<50 ppmv), and the outlet concentrations from
incinerators and carbon adsorbers are expected to often be below 50 ppmv.
Method 25. Method 25, "Determination of Total Gaseous Nonmethane
Organics Content" was also considered. A 30- to 60-minute integrated
sample is collected in a sample train, and the train is returned to the
laboratory for analysis. The collected organics are converted in several
analytical steps to methane and the number of carbon atoms (less methane in
the original sample) is measured. Results are reported as organic carbon
equivalent concentration. The Method 25 procedure is not recommended for
this industry because it is awkward to use for long test periods and it
takes integrated samples instead of continuously sampling and recording the
concentration. Concentration variations would be masked with Method 25
time-in teg rated sample. Also, Method 25 is not sensitive in low concentration
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ranges (<50 ppmv). However, Method 25 has the advantage that it counts each
carbon atom in each compound and does not have a varying response ratio for
different compounds.
D.2.3 Liquid Solvent Material Balance
If a plant's vapor processing device recovers solvent (such as carbon
adsorption or condensor systems) then a liquid solvent material balance
approach can be used to determine the efficiency of the vapor control
system. This is done by comparing the solvent used versus the solvent
recovered. These values may be obtained from a plant's inventory records.
The EPA has no test procedure to independently verify the plant's accounting
records. However, it is recommended that the plant set-up and submit to
the enforcement agency its proposed inventory accounting and record keeping
system prior to any performance testing.
For this performance testing approach, the averaging time (performance
test time period) usually needs to be 1 week to 1 month. This longer
averaging period allows for a representative variety of coatings and tape
products, as well as reducing the impact of short-term variations due to
process upsets, solvent spills, and variable amounts of solvent in use in
the process.
The volume of solvent recovered may be determined by measuring the level
of solvent in the recovered solvent storage tank. The storage tank should
have an accurate, easily readable level indicator. To improve the precision
of the volume measurement, it is recommended that the recovered solvent
tank have a relatively small diameter, so that small changes in volume
result in greater changes in tank level. Alternatively, the solvent recovered
may be measured directly by using a liquid volume meter in the solvent
return Tine. Adjustments to the amount of solvent recovered may be needed
to match the format of the applicable regulation. For example, if the
regulation applies to only certain unit operations in a plant, then the
contributions of other VOC sources must be subtracted from the total
amount of solvent recovered.
The volume of solvent used may be determined from plant inventory and
purchasing records or by measuring the level in the solvent storage tank.
Alternatively, a liquid volume meter can be used to measure the amount of
solvent drawn off from the solvent storage tank. Adjustments to the amount
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of solvent used may be needed to match the format of the applicable
regulation. For example, the regulation may apply to only certain unit
operations in a plant, or to only solvent applied at the coater not to
solvent used for cleanup.
D.3 MONITORING SYSTEMS AND DEVICES
The purpose of monitoring is to ensure that the emission control system
is being properly operated and maintained after the performance test. One
can either directly monitor the regulated pollutant, or instead, monitor an
operational parameter of the emission control system. The aim is to select
a relatively inexpensive and simple method that will indicate that the
facility is in continual compliance with the standard.
The three types of vapor processing devices that are expected to be used
in the plastic parts coating industry are carbon adsorbers, condensers, and
incinerators. Possible monitoring approaches and philosophy for each part
of the VOC control system are discussed below.
D.3.1 Monitoring of Vapor Processing Devices
D.3.1.1 Monitoring In Units of Efficiency. There are presently no
demonstrated continuous monitoring systems commercially available which
monitor vapor processor operation in the units of efficiency. This monitoring
would require measuring not only inlet and exhaust VOC concentrations, but
also inlet and exhaust volumetric flow rates. An overall cost for a complete
monitoring system is difficult to estimate due to the number of component
combinations possible. The purchase and installation cost of an entire
monitoring system (including VOC concentration monitors, flow measurement
devices, recording devices, and automatic data reduction) is estimated to be
$25,000. Operating costs are estimated at $25,000 per year. Thus, monitoring
in the units of efficiency is not recommended due to the potentially high cost
and lack of a demonstrated monitoring system.
D.3.1.2 Monitoring in Units of Mass Emitted. Monitoring in units of
mass of VOC emitted would require concentration and flow measurements only
at the exhaust location, as discussed above. This type of monitoring
system has not been commercially demonstrated. The cost is estimated at
$12,500 for purchase and installation plus $12,500 annually for operation,
maintenance, calibration, and data reduction.
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D.3.1.3 Monitoring of Exhaust VOC Concentration. Monitoring equipment
is commercially available, however, to monitor the operational or process
variables associated with vapor control system operation. The variable
which would yield the best indication of system operation is VOC concentration
at the processor outlet. Extremely accurate measurements would not be
required because the purpose of the monitoring is not to determine the
exact outlet emissions but rather to indicate operational and maintenance
practices regarding the vapor processor. Thus, the accuracy of a FIA (Method
25A) type instrument is not needed, and less accurate, less costly instru-
ments which use different detection principles are acceptable. Monitors
for this type of continuous VOC measurements, including a continuous recorder,
typically cost about $6,000 to purchase and install, and $6,000 annually to
calibrate, operate, maintain, and reduce the data. To achieve representative
VOC concentration measurements at the processor outlet, the concentration
monitoring device should be installed in the exhaust vent at least two
equivalent stack diameters from the exit point, and protected from any
interferences due to wind, weather, or other processes.
The EPA does not currently have any experience with continuous monitoring
of VOC exhaust concentration of vapor processing units in the magnetic tape
industry. Therefore, performance specifications for the sensing instruments
cannot be recommended at this time. Examples of such specifications that
were developed for sulfur dioxide and nitrogen oxides continuous instrument
systems can be found in Appendix B of 40 CFR 60. .
D.3.1.4 Monitoring of Process Parameters. For some vapor processing
systems, there may be another process parameter besides the exhaust VOC
concentration which is an accurate indicator of system operation. Because
control system design is constantly changing and being upgraded in this
industry, all acceptable process parameters for all systems cannot be
specified. Substituting the monitoring of vapor processing system process
parameters for the monitoring of exhaust VOC concentration is valid and
acceptable if it can be demonstrated that the value of the process parameter
is an indicator of proper operation of the vapor processing system. However,
a disadvantage of parameter monitoring alone is that the correlation of the
parameters with the numerical emission limit is not exact. Monitoring of any
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such parameters would have to be approved by enforcement officials on a case-
by-case basis. Parameter monitoring equipment would typically cost about
$3,000 plus $3,000 annually to operate, maintain, periodically calibrate,
and reduce the data into the desired format. Temperature monitoring equipment
is somewhat less expensive. The cost of purchasing and installing an
accurate temperature measurement device and recorder is estimated at $1,500.
Operating costs, including maintenance, calibration, and data reduction,
would be about $1,500 annually.
D.3.1.5 Monitoring of Carbon Adsorbers. For carbon adsorption vapor
processing devices, the preferred monitoring approach is the use of a
continuous VOC exhaust concentration monitor. However, as discussed above,
no such general monitor has been demonstrated for the many different organic
compounds encountered in this industry. Alternatively, the carbon bed
temperature {after regeneration and completion of any cooling cycles), and
the anount of steam used to regenerate the bed have been identified as
indicators of product recovery efficiency. Temperature monitors and steam •
flow meters which indicate the quantity of steam used over a period of time
are available.
D.3.1.6 Monitoring of Condensers. For condenser devices, the temperature
of the exhaust stream has been identified as an indicator of product recovery
efficiency, and condenser temperature monitors are available.
D.3.1.7 Monitoring of Incinerators. For incineration devices, the
exhaust concentration is quite low and is difficult to measure accurately
with the inexpensive VOC monitors. Instead, the firebox temperature has
been identified and demonstrated to be a process parameter which reflects
level of emissions from the device. Thus, temperature monitoring is the
recommended monitoring approach for incineration control devices. Since a
temperature monitor is usually included as a standard feature for incinerators,
it is expected that this monitoring requirement will not incur additional
costs to the plant.
D.3.1.8 Use of Monitoring Data. The use of monitoring data is the
same regardless of whether the VOC outlet concentration or an operational
parameter is selected to be monitored. The monitoring system should be
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Installed and operating properly before the first performance test. Continual
surveillance is achieved by comparing the monitored value of the concentration
or parameter to the value which occurred during the last successful performance
test, or alternatively, to a preselected value which is indicative of good
operation. It is important to note that a high monitoring value does not
positively confirm that the facility is out of compliance; instead, it
indicates that the emission control system or the coating process is operating
in a different manner than during the last successful performance test.
The averaging time for monitoring purposes should be related to the
time period for the performance test.
D.3.2 Monitoring of Vapor Capture Systems
D.3.2.1 Monitoring in Units of Efficiency. Monitoring the vapor
capture system in the units of efficiency would be a difficult and costly
procedure. This monitoring approach would require measuring the VOC concen-
tration and volumetric flow rate in the inlet to the vapor processing
device and in each fugitive VOC vent and then combining the results to
calculate an efficiency for each time period. Such a monitoring system has
not been commercially demonstrated. The purchase and installation of an
entire monitoring system is estimated at $12,500 per stack, with an additional
$12,500 per stack per year for operation, maintenance, calibration, and
data reduction. Thus, monitoring in the units of efficiency is not recommended.
D.3.2.2 Monitoring of Flow Rates. As an alternative, to monitoring
efficiency, an operational parameter could be monitored instead. The key
to a good capture system is maintaining proper flow rates in each vent.
Monitoring equipment is commercially available which could monitor these
flow rate parameters. Flow rate monitoring equipment for each vent would
typically cost about $3,000 plus $3,000 annually to operate, maintain,
periodically calibrate, and reduce the data into the desired format. The
monitored flow rate values are then compared to the monitored value during
the last successful performance test.
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Proper flow rates and air distribution in a vapor capture system could
also be ensured by an inspection and maintenance program, which generally
would not create any additional cost burden for a plant. In that case, the
additional value of information provided by flow rate monitors would probably
be minimal. Routine visual inspections of the fan's operation would indicate
whether or not capture efficiencies remain at the performance test level,
and no formal monitoring of the air distribution system would be required.
If a total enclosure is specified in the applicable regulation to
ensure proper capture, then the proper operation of the total enclosure
can be monitored. Examples of monitoring devices include VOC concen-
tration detectors inside the enclosure, pressure sensors inside the
enclosure, flow rate meters in ducts, and fan amperage meters.
D.3.3 Monitoring of Overall Control System Efficiency on a Liquid Basis
If a plant uses a vapor recovery control device, the efficiency of the
overall plant control (combined vapor capture and vapor recovery systems) can
be monitored using a liquid material balance. (These amounts may need to be
adjusted to match the format of the applicable regulation.) The amount of
solvent used is compared to the amount of solvent recovered. These values
are obtained from a plant's inventory records. For this monitoring approach,
the averaging time or monitoring period usually needs to be 1 week to 1 month
This longer averaging period is necessary to coordinate with a plant's
inventory accounting system and to eliminate short-term variations due to
process upsets, solvent spills, and variable amounts of solvent in use in
the process.
Because most plants already keep good solvent usage and inventory records,
no additional cost to the plant would be incurred for this monitoring approach.
D.3.4 Monitoring of Coatings
If a plant elects to use low-solvent content coatings in lieu of control
devices, then the VOC content of the coatings should be monitored. There is
no simplified way to do this. Instead, the recommended monitoring procedure
is ths same as the performance test: the plant must keep records of the VOC
content and amount of each coating used and calculate the weighted average
VOC content over the time period specified in the regulation.
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D.4 TEST METHOD LIST AND REFERENCES

The EPA testing methods that are mentioned in this Appendix are listed
below with their complete title and reference.
D.4.1 Reference Methods in Appendix A - 40 CFR 60
Method 1 - Sample and Velocity Traverses for Stationary Sources.
Method 2 - Determination of Stack Gas Velocity and Volumetric
Flow Rate (Type S Pi tot Tube).
Method 2A - Direct Measurement of Gas Volume Through Pipes and
Small Ducts.
Method 3 - Gas Analysis for Carbon Dioxide, Excess Air, and Dry
Molecular Weight.
Method 4 - Determination of Moisture in Stack Gases.
Method 18 - Measurement of Gaseous Organic Compound Emissions by
Gas Chromatography.
Method 21 - Determination of Volatile Organic Compound Leaks.
Method 24 - Determination of Volatile Matter Content, Water Content,
Density, Volume Solids, and Weight Solids of Surface Coatings,
Method 24A- Determination of Volatile Matter Content and Density of
Printing Inks and Related Coatings.
Method 25 - Determination of Total Gaseous Nonmethane Organic Emissions
as Carbon.
Method 25A- Determination of Total Gaseous Organic Concentration Using
a Flame lonization Analyzer.
Method 25B- Determination of Total Gaseous Organic Concentration Using
a Nondispersive Infrared Analyzer.
D.4.2 Proposed Methods for Appendix A - 40 CFR 60
Method 1A - Sample and Velocity Traverses for Stationary Sources With
Small Stacks or Ducts (Proposed on 10/21/83, 48 FR 48955).
Method 2C - Determination of Stack Gas Velocity and Volumetric Flow
Rate From Small Stacks and Ducts (Standard Pi tot Tube)
(Proposed on 1U/21/83, 48 FR 48956).
Method 2D - Measurement of Gas Volume Flow Rates in Small Pipes and
Ducts (Proposed on 10/21/83, 48 FR 48957).
D-23
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D.4.3 Other Methods
"General Measurement of Total. Gaseous Organic Compound Emissions
Using a Flame lonization Analyzer," in "Measurement of Volatile
Organic Compounds Supplement 1," OAQPS Guideline Series, EPA Report
No. 450/3-82-019, July 1982.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing/
1. REPORT NO.
EPA-450/3-85-019a
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Surface Coating of Plastic Parts for Business
Machines—Background. Information for Proposed
Standards
5. REPORT DATE
December 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3817
12. SPONSORING AGENCY NAME AND ADDRESS
Director for Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Triangle Park. North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT '• ~~~—~"~~"~~~~""~~~~"~~^~~~~"""~"~~~———————^—^——

Standards of Performance for the control of VOC emissions from affected facilities
that perform exterior surface coating of plastic parts for business machines are
being proposed under authority of Section 111 of the Clean Air Act. These standards
would apply to each new, modified, and reconstructed spray booth in which plastic
P^[tS !?r 5us1ness mach1nes are surface coated and that commence construction on or
after the date of proposal of the regulation. This document contains background
information and environmental and economic impact assessments of the regulatory
alternatives considered in developing the proposed standards.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Pollution Control
Standard of Performance
Exterior Surface Coating
Business Machine
Volatile Organic Compounds
Plastic Part
Air Pollution Control
13B
8. DISTRIBUTION STATEMENT

Unlimited
19. SECURITY CLASS (ThisReport}
Unclassified
21. NO. OF PAGES
275
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220—1 (Rev. 4—77) PREVIOUS EDITION is OBSOLETE
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